JFSC 2025 Financial Crime Examination Feedback – Key findings and what firms need to do

The paper summarises findings from the JFSC's 2025 financial crime examinations. It is designed to help firms assess the effectiveness of their systems and controls for preventing and detecting financial crime and to support compliance with Jersey's legal and regulatory framework.

It covers five areas with key findings, practical examples of good practice, and self-assessment prompts.

• Corporate governance
• Identification measures
• Ongoing monitoring
• Enhanced and simplified client due diligence measures and exemptions
• Reporting requirements

Key Findings and What Firms Need to Do

• Corporate Governance Common issues:
• BRAs not reviewed/updated or incomplete (missing PF risk or cumulative impact);
• No or weak financial crime strategy and risk appetite.
• Inadequate board oversight and minutes.
• P&Ps untailored, outdated or copied from the Handbook.
• Weak CMP testing and documentation.
• MLRO/MLCO conflicts and resourcing not properly managed.
• No clear risk appetite statement (RAS).[Just under half of entities with governance findings lacked a RAS]
• Corporate Governance - What firms need to do:
• Update BRAs to cover all risks with documented controls and cumulative impact assessment.
• Define and apply a clear risk appetite and strategy.
• Please ensure the board minutes show proper oversight and approvals.
• Create detailed, tailored, version-controlled P&Ps. Run robust CMP tests with documented remediation and board reporting.
• Assess and mitigate MLRO/MLCO conflicts.
• Confirm adequate resourcing and effectiveness.
• Identification Measures: Common issues:
• Inconsistent or missing identification evidence; weak customer understanding (ownership, control, source of funds/wealth);
• Flawed CRA methodologies (missing TF/PF/adverse media factors, subjective scoring, no updates on triggers);
• Poor oversight of overrides and incomplete CRAs.
• Identification Measures - What firms need to do:
• Apply identification measures consistently and on time with verifiable evidence.
• Document comprehensive customer profiles and understanding.
• Use a robust CRA methodology that covers all risk factors, with a clear rationale and trigger-based updates.
• Implement documented oversight for approvals and overrides.
• Complete CRAs for all relevant parties and keep them current.
• Ongoing Monitoring Common issues:
• Periodic reviews overdue and ineffective, with outstanding actions; monitoring not risk-based;
• Incomplete or inconsistent screening (sanctions/PEPs/adverse media) with poor hit handling,
• Undocumented rationale and backlogs.
• P&Ps missing key screening processes.
• Ongoing Monitoring: What firms need to do:
• Ensure timely, risk-based periodic reviews with tracked actions and approvals.
• Conduct a complete screening of all relevant parties, review hits promptly with a documented rationale, clear backlogs, and test effectiveness.
• Update P&Ps to cover the full screening process.
• Please report on review timeliness, backlogs, and resolutions to senior management/board.
• Enhanced and Simplified CDD Measures and Exemptions. Common issues:
• ECDD not applied risk-sensitively.
• Inadequate or uncorroborated source of wealth.
• Missing P&Ps for PEP identification and ECDD.
• Exemptions used without proper evidence.
• Risk assessment against Article 17A criteria; or
• Consideration of higher-risk customers.
• Enhanced and Simplified CDD Measures and Exemptions: What firms need to do:
• Apply ECDD proportionately with robust, corroborated and documented source of wealth.
• Establish clear P&Ps for PEP identification (including family/associates) and ECDD.
• Only use exemptions where justified with documented risk assessment;
• Avoid higher-risk cases.
• Record and reassess ongoing appropriateness.
• Reporting Requirements: Common issues:
• SAR registers missing key dates (especially when information first came to attention);
• incomplete SAR P&Ps;
• MLRO decision-making and enquiries not documented;
• Delays or improper handling (e.g. transactions after internal SAR without FIU consent).
• Enhanced and Simplified CDD Measures and Exemptions - What firms need to do:
• Record all required dates distinctly in SAR processes. Update P&Ps to cover timely submission, MLRO oversight and other obligations.
• Document all MLRO enquiries and decisions.
• Prevent transactions proceeding post-internal SAR without proper assessment/consent.
• Train staff on red flags and escalation; report SAR statistics to the board.

Overall message from the paper

• Core risks remain consistent with prior years, but many firms still struggle to embed and evidence effective controls.
• Weaknesses are often interconnected.
• Firms should use the self-assessment prompts in the full PDF to identify gaps in their own frameworks and take proactive, timely action.

• Read the full document using the two URLs above for the detailed findings, good practice examples and self-assessment questions. The JFSC invites feedback via survey (by 31 July 2026) or email to FSCFCEU@jerseyfsc.org.

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JFSC 2025 financial crime examination feedback – published June 2026

The JFSC has published a feedback paper which sets out the key findings from the financial crime examinations conducted in 2025. Its purpose is to help you assess the effectiveness of your systems and controls in preventing and detecting financial crime and to support compliance with Jersey's legal and regulatory framework.

The paper covers findings from examinations, along with practical examples of good practice and self-assessment prompts, covering:

• Corporate governance
• Identification measures
• Ongoing monitoring
• Enhanced and simplified client due diligence measures and exemptions
• Reporting requirements

By reflecting on these findings, you can identify any gaps in your own framework and take proactive steps to strengthen your controls to prevent and detect financial crime.

Read the full feedback paper.

https://www.jerseyfsc.org/news-and-events/read-our-2025-financial-crime-examination-feedback/

https://www.jerseyfsc.org/media/y1rllx0d/2025-financial-crime-examination-feedback.pdf

(The first is the JFSC news page; the second is the full official PDF published 29 June 2026.)