Jersey keeps sending the dirty money home. MONEYVAL asked for prosecutions.

Jersey is good at taking other people’s dirty money out of its banks and sending it home. That is different from prosecuting money laundering as a crime in its own right.

John Cusack, chair of the Global Coalition to Fight Financial Crime, said so on the day the 2024 report landed.

• Jersey is “probably in the top 10 countries on a relative basis for taking away people’s money” because the money is sitting here.

• It is “doing better than many at taking away the money, but is not doing as well as it should be at prosecuting money laundering cases and putting people behind bars.”

Concerning leg one of Cusack’s arguments,

• Jersey continues to freeze, seize, and return dirty money - this was highlighted again this week (17 Sept 2026)

  • The Law Officers returned $667,000 belonging to Gustavo Geraldes, convicted in 2022 of a COVID-era Medicare kickback scheme, to the United States.

  • https://www.comsuregroup.com/news/jersey-returns-proceeds-of-crime-667-000-after-covid-era-medicare-kickback-conviction/

What we are missing is leg 2, of Cusack’s arguments,

• The harder task of prosecuting money laundering cases and putting people behind bars

What is on the record

MONEYVAL’s Fifth Round Mutual Evaluation Report (on-site 27 September–10 October 2023; adopted May 2024) rated confiscation

• Substantial and ML investigation and prosecution

• Moderate. Moderate means major improvements are required. Technical compliance was strong: 39 of 40 recommendations were compliant or Largely Compliant.

On prosecutions, the report is explicit.

• “The number of prosecutions and convictions for ML, for the period under review, is low and not in line with the jurisdiction’s context as an IFC and its risk profile.” (paragraph 246)

  • “There is only one conviction for stand-alone or autonomous ML,

  • Whereas third-party laundering convictions are very rare,

• Which is not in line with the jurisdiction’s context as an IFC and its risk profile.” (paragraph 252)

The Jersey Money laundering cases - Selfies, Autonomous and Third Parties can be shown as:-

• Most convictions were for self-laundering. For example, the thief who also hides the cash.

  • The biggest case in Jersey is Jeanne and Timms at Jersey Mutual.

    • A 2026 case shows Martin John Hill, former Isle of Wight hotelier (Burlington Hotel, Sandown; Shanklin Beach Hotel). Now of Alicante. He committed the predicate (UK VAT fraud) and then moved the same money through Jersey.  It sits outside the MER window.

• One third-party conviction –

  • The worked third-party example was Central Market jeweller Darius Pearce: 7½ years for washing drug cash through gold in Hatton Garden.

    •  A 2026 family case — Mariela Josefina Gomez Marquez, guilty of putting more than £37,000 of her son’s cocaine cash through her account — is third-party ML. It sits outside the MER window.

• One stand-alone autonomous conviction - The MER does not name the single autonomous conviction. T

  • He closest public case in that window is Umurzokov, Eshonkulov and Bataa (April 2022, 22 counts, up to four years): a professional team, predicate not proved at trial, convictions on “irresistible inference.”

  • Later UK reporting on Operation Destabilise tied that network to drugs and prostitution proceeds.

No banks or other financial services

• None of the above are financial/professional services convicted of laundering third-party proceeds.

• What we have seen is that prosecutions of financial/professional services for failure to have adequate systems-and-controls cases; however, this is not the MoneyVal targeted offence.

Jersey’s corporate AML criminal record is short, and it does not include any laundering convictions.

• Caversham and Bell (2005) is the sentencing baseline.

  • Still the sentencing baseline because it was the first MLO prosecution of its kind in Jersey (and, the Court said at the time, in the British Isles).

•  Two firms have been fined in the Royal Court for Money Laundering Order failures (systems and controls under Article 37(4) of the Proceeds of Crime Law): they missed risk; they did not apply CDD.

  • Abu Dhabi Commercial Bank PJSC, Jersey Branch — 5 February 2020 and LGL Trustees Limited — 19 February 2021  

  • Neither case found that the customer’s money was itself laundered.

• A third, older file. The lawyer is Kevin Robert Manning, solicitor (écrivain) of the Royal Court, firm K R Manning & Co.

  • He is an MLO count bolted onto his own fraud, not a third-party IFC laundering case. He took client and curatorship money to prop up the practice, then pleaded guilty to failing to keep accurate client records for six years, contrary to the Money Laundering Order (Article 37 POCL).

  • Sentenced 12 December 2018: 3½ years — 20 counts of fraudulent conversion, one fraudulent conversion as trustee, one MLO failure. Deficit of about £65,000–£94,000. Struck off. Pension later taken in confiscation.

• In December 2024, the Island added its first Deferred Prosecution Agreement (DPA)

  • With Afex Offshore — MLO-style counts, a fine, no conviction. MONEYVAL treated this family of outcomes as a useful alternative rather than as Immediate Outcome 7.

• The outcomes

  • Caversham Fiduciary / Bell — 2005 — MLO baseline.

  • Kevin Robert Manning — sentenced 12 December 2018 — fraud + one MLO count — 3½ years.

  • Abu Dhabi Commercial Bank PJSC, Jersey Branch — 5 February 2020 — MLO — £475,000 + £25,000 costs.

  • LGL Trustees Limited — 19 February 2021 — MLO — £550,000 + £50,000 costs.

  • Afex Offshore (Jersey) Limited — DPA 18 December 2024 — not a conviction — £408,240 + £60,000 costs.

• None of the 5 is the MoneyVal targeted offence.

What about the money

• Compared to the above prosecutions, Jersey has been better at freezing, seizing and returning the money, as can be shown here:-

Three ledgers, but do not add them.

• Ledger 1 — MONEYVAL, 2018 to 2023 on-site.

  • Total recovered: €311 million. About €280 million was one file: Abacha / Doraville.

  • Jersey enforced a US civil forfeiture order and, under the February 2020 tripartite agreement, repatriated more than US$300 million to Nigeria.

  • Strip that out, and Jersey court orders in the same window are about €31 million.

  • Table 8.1: €30.9 million into the COCF from domestic post-conviction and domestic civil forfeiture, 2018–2022 — roughly €6 million a year.

  • “Domestic” means a Jersey court made the order, not that the crime happened here.

• Ledger 2 — official repatriations, 2024–25.

  • States Annual Report: £7,651,027 sent overseas in 2025 and £3,133,204 in 2024 — £10.8 million, up 114 per cent.

  • ECCU reports almost £3 million confiscated across four unnamed 2025 cases.

  • Only Jeanne/Timms (£656,193) is in a public press release.

• Ledger 3 — named returns.

  • Nigeria $9.5 million; Brazil £725,783; Mozambique £829,500; Benzur £397,000 shared with the UK; Jeanne/Timms £656,193; Geraldes $667,000.

  • Same pattern: money parked here, then sent home.

  • Some of these are included in the £10.8 million. Stacking them produces a fake total. Do not do it.

€311 million is not comparable to £10.8 million.

• Different years, different currencies, different mix of foreign orders versus Jersey court orders.

• Most of the MONEYVAL headline was another jurisdiction’s judgment, enforced because the assets were here.

Conclusion

• Civil forfeiture (lots see above), one DPA (one prosecution) and the introduction of a failure-to-prevent money laundering offence (no prosecutions) were recognised by MONEYVAL as useful.

  • They were not treated as a substitute for prosecutions that match an IFC’s risk profile.

• The Government High-Level Action Plan and the JFSC’s 25 recommended actions exist because

  • The evaluators required more large-scale ML cases involving foreign predicates and complex structures.

• Jersey can defend the Substantial confiscation rating. It has not met Immediate Outcome 7.

  • Two years of £10.8 million in repatriations and

  • This week’s $667,000 does not change that.

• However, until third-party and autonomous cases involving Jersey structures reach the Royal Court in numbers that match the threat, sending the money home remains the easier half of the job.

End

Sources

• Annex 2 – Non-Ministerial Department Reports (Law Officers’ Department):
  “£7,651,027 funds repatriated to overseas jurisdictions from Asset Recovery Agreements negotiated in 2025 — 114% up on the £3,133,204 in 2024.”

• Part 1 – Performance Report (same KPI box for the Law Officers’ Department):
  “£7,651,027 in funds repatriated to overseas jurisdictions — 2024 was £3,133,204.”

• Source PDF:
  https://www.gov.je/SiteCollectionDocuments/Government%20and%20administration/Annual%20Report%20and%20Accounts%202025%20Annex%202%20Non-Ministerial%20Department%20Reports.pdf
  https://www.gov.je/SiteCollectionDocuments/Government%20and%20administration/Annual%20Report%20and%20Accounts%202025%20Part%201%20Performance%20Report.pdf

Sources for verification

• BBC News, Geraldes return, 15 Sept 2026: https://www.bbc.co.uk/news/articles/c623xrv9v1j7o

• Bailiwick Express, same case, 16 Sept 2026: https://www.bailiwickexpress.com/news/us-covid-fraudsters-money-returned-to-victims/

• Bailiwick Express, MONEYVAL results day / John Cusack interview, 24 July 2024: https://www.bailiwickexpress.com/news/digest-what-does-moneyval-make-jersey/

• MONEYVAL Fifth Round Mutual Evaluation Report of Jersey, May 2024 (IO.7 paras 246 and 252; IO.8 paras 287–288 and Table 8.1): https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/Jersey-MER-2024.pdf.coredownload.inline.pdf

• MONEYVAL press release, 24 July 2024: https://www.coe.int/en/web/moneyval/-/moneyval-acknowledges-jersey-s-progress-in-improving-measures-to-combat-money-laundering-and-financing-of-terrorism

• FATF Jersey MER landing page: https://www.fatf-gafi.org/en/publications/Mutualevaluations/MER-Jersey-2024.html

• Government of Jersey High-Level Action Plan: https://www.gov.je/SiteCollectionDocuments/Industry%20and%20finance/R%20MONEYVAL%20High%20Level%20Action%20Plan.pdf

• JFSC MONEYVAL evaluation page: https://www.jerseyfsc.org/industry/international-co-operation/international-assessments/moneyval/2024-moneyval-evaluation

• JFSC action plan (25 recommended actions): https://www.jerseyfsc.org/media/7911/jfsc_moneyval-action-plan_final.pdf

• JFSC March 2026 progress update: https://www.jerseyfsc.org/media/4rxcb15f/jfsc-moneyval-report-update.pdf

• States of Jersey Annual Report and Accounts 2025, Annex 2: https://www.gov.je/SiteCollectionDocuments/Government%20and%20administration/Annual%20Report%20and%20Accounts%202025%20Annex%202%20Non-Ministerial%20Department%20Reports.pdf

• Law Officers’ Department, Jeanne/Timms confiscation: https://www.lawofficersje.je/publications/news/complex-fraud-and-money-laundering

• Law Officers’ Department news index: https://www.lawofficersje.je/publications/news

The 5 cases

1. Caversham Fiduciary / Bell — 2005

• Sentencing: https://www.bailii.org/je/cases/UR/2005/2005_165.html

• No-case ruling: https://www.jerseylaw.je/judgments/unreported/Pages/%5B2005%5DJRC143.aspx

• Appeal: https://www.jerseylaw.je/judgments/unreported/Pages/%5B2006%5DJCA014.aspx

• JEP, 26 November 2005: https://jerseyeveningpost.com/news/2005/11/26/financial-services-group-fined-100000/

2. Kevin Robert Manning — 12 December 2018

• Comsure note of strike-off / counts: https://www.comsuregroup.com/news/jersey-lawyer-removed-from-the-roll-of-solicitors-of-the-royal-court-for-following-fraud-and-money-laundering-conviction/

• Bailiwick Express, confiscation / pension, 30 May 2019: https://www.bailiwickexpress.com/news/disgraced-former-lawyer-surrender-pension/

3. Abu Dhabi Commercial Bank PJSC, Jersey Branch — 5 February 2020

• Sentence: https://www.jerseylaw.je/judgments/unreported/Pages/%5B2020%5DJRC022.aspx

• Reasons: https://www.jerseylaw.je/judgments/unreported/PDFs/%5B2020%5DJRC059.pdf

• International Adviser summary: https://www.international-adviser.com/uae-bank-fined-600k-over-money-laundering-risk/

4. LGL Trustees Limited — 19 February 2021

• LOD press release: https://www.lawofficersje.je/publications/news/breaches-of-money-laundering-order

• Reasons: https://www.jerseylaw.je/judgments/unreported/Pages/%5B2021%5DJRC058.aspx

• PDF: https://www.jerseylaw.je/judgments/unreported/PDFs/%5B2021%5DJRC058.pdf

5. Afex Offshore (Jersey) Limited — DPA 18 December 2024

• LOD, published DPA papers: https://www.lawofficersje.je/publications/news/publication-of-related-documents

• Bedell Cristin briefing: https://www.bedellcristin.com/knowledge/briefings/fy-2425/q2/key-points-for-regulated-financial-services-providers-from-jerseys-first-deferred-prosecution-agreement/

BAILII judgment: http://www.bailii.org/je/cases/UR/2024/2024_271.html