Jersey Sanctions Reporting obligations for financial services, lawyers, accounts, estate agencies, etc.
Jersey Relevant Financial Institution* [Inc. lawyers, accounts, estate agencies] must know their financial sanctions reporting obligations
An outline of sanction obligations are:
On the Government of Jersey website, and
On the Jersey Financial Services Commission's (JFSC) website.
Financial sanctions reporting obligations are set out in Article 32 of the Sanctions and Asset-Freezing (Jersey) Law 2019 and apply to all sanctions regimes in force.
These obligations include requirements for a relevant financial institution* to report/inform the Minister of a sanctioned act or a suspicion of the act
- Relevant Financial Institution* [A Jersey FI]
- The definition of a relevant financial institution can be found in Article 1 of the Sanctions and Asset-Freezing (Jersey) Law 2019. This definition includes:
- All financial services businesses regulated by the JFSC under regulatory laws, as specified in Part A Schedule 2 of the Proceeds of Crime (Jersey) Law 1999;
- Certain other financial services businesses listed in Part B Schedule 2 of the Proceeds of Crime (Jersey) Law 1999;
- A person (not being an individual) that is incorporated or constituted under the law of Jersey and carries on such financial services business in any part of the world.
The test for reporting to the Minister is as follows:
- A JERSEY FI:
- Holding an account of a person,
- Entering into dealings or an agreement with a person or
- Being approached by or on behalf of a person, and
- And the JERSEY FI knows or has reasonable cause to suspect that the person:
- Is a designated person, or;
- Has committed an offence, and
The basis of the information or other matter on which the knowledge or reasonable cause for suspicion came to a JERSEY FI in the course of carrying on its business.
a JERSEY FI should use the Sanctions Compliance Reporting Form available from the JFSC website to report any suspected breach of financial sanctions and return the completed form to email@example.com
These reporting obligations are in addition to the obligation to report suspicious activities to the Financial Intelligence Unit.
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