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Jersey - Unauthorised Schedule 2 business deals with criminal property - no convictions or regulatory sanctions to date

The JFSC has highlighted on its website the following JERSEY events
  • A couple involved in the distribution and sale of drugs attempted to launder £20,000.
  • They tried to exchange Jersey £20 notes into English notes, deposit the cash into UK bank accounts and buy goods to be re-sold later.
  • The couple initially approached local banks. The banks followed their internal policies on handling cash and refused to accept a cash deposit due to the amount and unexplained/undocumented source.
  • The couple also approached a local car dealership.
  • The dealership was not registered as a high-value dealer as its policy did not take significant cash payments. They refused to sell vehicles for cash.
  • The couple then decided to approach a smaller retailer stocking a wide range of electronics and they bought some expensive laptops, computers and smartphones.
The JFSC suggest the failure consequence
  • The retailer was not registered as a high-value dealer and did not have policies on accepting significant cash payments.
  • So, despite the bill totalling over £20,000, the staff processing the transaction did not become suspicious and did not query the origin of the cash.
  • They accepted transactions that fall within the high value dealer definition in the Proceeds of Crime Law.
  • If they were registered as a high value dealer, they would have appropriate systems and controls in place, apply CDD and BRA measures to the couple and may have been suspicious of the nature of the transaction.
  • The business in this example appears to be involved in money laundering and may be found guilty of the offence of dealing with criminals.
  • As an unregistered high value dealer may be also found guilty of the offence of carrying on unauthorised specified Schedule 2 business.
  • in addition, it appears that the business should have been registered with the JFSC so may be found to have broken Anti Money Laundering (AML) / Countering the Financing of Terrorism (CFT) Codes of Practice within the Handbook and may be subject to proceedings by the JFSC.
  • As of today [21 March 2023], Comsure is unaware of any action being taken against the  smaller retailer of electronic goods


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