Jersey set to toughen SANCTIONS REPORTING RULES under new amendment regulations – TARGET MARCH 2026

Jersey is preparing to significantly strengthen its sanctions enforcement regime as the Draft Sanctions and Asset Freezing Law (Jersey) Amendment Regulations 202 move toward debate in the States Assembly.

The proposed Regulations officially lodged at the Greffe on 22 January 2026 represent the island’s latest step in aligning its sanctions framework with evolving international standards and recent changes to UK legislation.

A Strategic Update to Jersey’s Sanctions Architecture

• The Draft Regulations aim to enhance and modernise the Sanctions and Asset‑Freezing (Jersey) Law 2019 (SAFL), the island’s primary legal mechanism for implementing both UN sanctions and autonomous UK sanctions.
• The amendments ensure that Jersey maintains regulatory consistency with the UK’s post-2024 reforms, particularly around definitions and reporting duties.  
• Under the current framework, SAFL operates alongside the Sanctions and Asset Freezing (Implementation of External Sanctions) (Jersey) Order 2021, which incorporates UK sanctions instruments into Jersey law with modifications.
• This structure allows Jersey to mirror international sanctions regimes while retaining local oversight powers.

Key Amendments Proposed in the Draft Regulations

1. Clearer Definitions on Indirect Provision of Resources

• Regulations 2 and 4 provide new clarity on what constitutes “making available indirectly to, or for the benefit of, a designated person” in relation to funds, financial resources, or economic resources.
• This change mirrors UK legislative updates introduced in 2024, ensuring Jersey’s interpretation remains aligned with global expectations and enforcement practice.
• [statesassembly.je]

2. Stronger Reporting Obligations for Financial Institutions

• One of the most impactful changes comes under Regulation 3, which amends Article 32(1) of SAFL.
  Currently, a financial institution must report concerns to the Minister only if it has a direct connection to the individual, such as holding an account or transacting with the individual.
• The Draft Regulations remove these connection criteria, meaning that any relevant financial institution, during the course of its business, must report if it knows or suspects that a person is designated or involved in an offence under SAFL, regardless of any prior relationship.
  This represents a major escalation in Jersey’s expectations for detection and reporting across the sector.  
• This shift aligns with previous reporting-focused amendments made between 2019 and 2023 and continues the island’s trend of tightening due diligence and disclosure requirements.  

3. Expanded Ministerial Powers to Disclose Information

• Regulation 5 broadens the Minister for External Relations’ authority under Article 36 of SAFL.
• If satisfied that disclosure is appropriate, the Minister will be permitted to share a wider range of information with an expanded set of domestic and international bodies.
• This strengthening of information‑sharing aligns with global efforts to close regulatory gaps exploited for sanctions evasion.  

4. Swift Implementation Timelines

• Should the State Assembly approve the Draft Regulations, they will come into force seven days after being enacted.
• Government reports confirm that no additional staffing or financial burdens are anticipated, suggesting the regulatory infrastructure already exists to support the enhanced regime.  

Why These Reforms Matter

The timing of the amendments reflects the increasing geopolitical complexity surrounding sanctions enforcement. Jersey, as a significant international finance centre, faces continual pressure to demonstrate:

• Robust alignment with UK and UN sanctions frameworks
• Effective local enforcement mechanisms
• Transparent, timely reporting pathways for institutions handling assets vulnerable to misuse

With sanctions becoming a preferred tool of foreign policy, particularly in relation to Russia, Iran, and global terrorism financing networks, Jersey’s enhancements ensure it remains a trusted, compliant jurisdiction with minimal reputational risk.

JFSC

• The Jersey Financial Services Commission has steadily reinforced the legal framework through various amendments between 2019 and 2025, addressing definitions, reporting obligations, transparency measures, and the island’s ability to implement expanded sanctions regimes.
• These new 2026 Regulations continue that trajectory.
• [jerseyfsc.org]

Next Steps: Debate Scheduled for March 2026

• The earliest date for the State Assembly debate is 10 March 2026, after which the Regulations may be adopted and brought rapidly into force.
• If passed, these measures will solidify Jersey’s alignment with UK and UN expectations, reinforcing its standing as a jurisdiction committed to preventing financial crime, sanctions evasion, and the abuse of its financial system.  
• Summary The Draft Sanctions and Asset-Freezing Law (Jersey) Amendment Regulations 202‑ would, if adopted by the States, ensure that Jersey’s sanctions‑implementation framework remains aligned with the United Kingdom, where appropriate and that the Minister for External Relations continues to meet international obligations as Jersey’s competent authority for sanctions.

The Regulations would also:

• Clarify the meaning of “making available indirectly to, or for the benefit of, a designated person” in relation to economic resources, funds, or financial resources, following equivalent amendments made in UK sanctions law in 2024.  
• Expand reporting duties under Article 32 of the Sanctions and Asset‑Freezing (Jersey) Law 2019 by removing the requirement that a financial institution must have a direct connection with the person (e.g., account holder or counterparty). Instead, institutions must report if, in the course of business, they know or suspect a person is designated or has committed, is committing, or intends to commit a sanctions offence.  
• Increase the Minister’s disclosure powers by expanding the types of information that may be shared and the entities to whom disclosure may be made, provided disclosure is considered appropriate.
• Bring the Regulations into force seven days after adoption, with no anticipated financial or staffing implications for the Government of Jersey.  

 Longer read

Jersey Sanction reporting obligations are set to widen under the proposed draft sanctions regulation update.

Draft Sanctions and Asset-Freezing Law (Jersey) Amendment Regulations 202-

The Draft Sanctions and Asset-Freezing Law (Jersey) Amendment Regulations 202- would, if adopted by the States,

• Ensure that sanctions implementation in Jersey remains aligned with the UK, where appropriate.

A key change is Regulation 3 (which amends Article 32(1) of the Sanctions and Asset Freezing Law 2019 (‘SAFL)), which currently:-

• Requires a relevant financial institution to provide the Minister with information about a person where it knows or has reasonable cause to suspect, as a result of information obtained in the course of its business, that the person is a designated person or has committed, is committing or intends to commit an offence under the SAFL.

Under SAFL, this requirement only applies currently  in circumstances  where  the financial institution

• Has a connection to the person (i.e., that it holds an account of the person,
• Has entered into dealings or an agreement with the person, or
• Has been approached by or on behalf of the person.

The proposed regulations remove these specific criteria.

• If, in the course of carrying on its business, a relevant financial institution knows, or has reasonable cause to suspect, that a person is a designated person or has committed, is committing or intends to commit an offence under SAFL, it is obliged to report to the Minister.

Sources

• [statesassembly.je], https://statesassembly.je/getmedia/adfbe7e8-9071-4a37-9e70-754a82f41cd0/P-10-2026.pdf?ext=.pdf
• [statesassembly.je] https://statesassembly.je/publications/propositions/2026/p-10-2026
• [gov.je] https://www.gov.je/Government/PlanningPerformance/Pages/MinisterialDecisions.aspx?docid=920DC1AE-20F3-4539-A2BC-47B5E442936A
• [jerseylaw.je] https://www.jerseylaw.je/laws/current/ro_11_2021_20250722