JFSC 2025 SAR Thematic Examination Feedback – What MLROs and Compliance Teams Must Do Now

The Jersey Financial Services Commission has released its long-awaited feedback from the 2025 thematic examination on suspicious activity reporting (SAR).

• Published on 27 May 2026, the paper provides clear direction for MLROs and compliance professionals on where firms are performing well and where immediate improvements are needed.
• The review examined nine supervised persons and was prompted by recommendations in Jersey's 2024 MONEYVAL Mutual Evaluation Report.
• While the overall picture is positive, the findings highlight several recurring weaknesses that every Jersey firm should review.

Headline Results

• 4 out of 9 firms examined received no findings — demonstrating that strong SAR frameworks are achievable.
• All firms received feedback.
• Firms with deficiencies were required to submit formal remediation plans to their JFSC supervisor.

Most common areas of deficiency:

• Policies and procedures not updated to current requirements
• Incomplete SAR registers and records
• Role, independence and oversight of the MLRO (including DMLRO support)

Other findings related to:

• Board oversight of reporting timeliness,
• MLRO training,
• Compliance monitoring of SAR controls and
• Some firms also needed to manage conflicts of interest better where the MLRO carried out client-facing work.

What the JFSC Found – Good Practice vs Poor Practice

• The feedback includes a helpful table of findings and examples of best practice.

Key highlights include:

• Board Oversight
• Poor: Boards failing to demonstrate adequate oversight of the timeliness of MLRO decisions to file eSARs.
• Good: Board minutes clearly document discussion, scrutiny and challenge of SAR timeliness.
• Policies & Procedures (most common issue)
• Poor: Out-of-date policies missing requirements for the MLRO to update the FIU with additional information, or lacking a disciplinary process for staff who fail to raise an iSAR.
• Good: Clear, current, easily accessible policies with templates; regularly reviewed; embedded across the business.
• SAR Register & Records (most common issue)
• Poor: Missing key data fields, incomplete records of enquiries, and inadequate supporting CDD/source of wealth documentation.
• Good: Comprehensive registers with all required dates, identities, rationale for decisions, and a clear audit trail.
• MLRO Role & Independence (most common issue)
• Poor: Lack of evidence that the MLRO is actively overseeing and supporting any DMLRO; unclear job descriptions; conflicts of interest not properly mitigated.
• Good: Detailed job descriptions, regular documented oversight meetings between MLRO and DMLRO, and a clear conflict register with mitigations.
• Training
• Poor: MLROs not receiving ongoing or role-specific training.
• Good: Targeted training covering iSAR handling, FIU liaison, tipping-off risks, and production/restraining orders.
• Compliance Monitoring
• Poor: Weak or insufficient testing of SAR systems and controls.
• Good: Robust, risk-based testing with results escalated to the board and remediation tracked to completion.

Your Core Obligations – Quick Reminder

• Firms and employees have clear duties under the Proceeds of Crime (Jersey) Law 1999, Terrorism (Jersey) Law 2002, Money Laundering (Jersey) Order 2008, and the AML/CFT/CPF Handbook (Section 8, moving to Section 9 from 31 May 2026).
• These include maintaining effective internal reporting systems, ensuring prompt escalation of suspicions, protecting against tipping off, and making timely external reports to the FIU Jersey where required.
• Failure to report knowledge or suspicion remains a criminal offence.

What MLROs and Compliance Teams Should Do Now

The JFSC encourages all supervised persons to review the feedback and assess their own systems and controls. Recommended immediate actions:

1. Conduct a gap analysis against the JFSC's good practices and the seven key self-assessment questions in the paper (see below).
2. Prioritise the three most common issues: Update policies and procedures, strengthen the SAR register and record-keeping, and formalise MLRO/DMLRO oversight and independence.
3. Enhance board reporting — ensure the board receives clear information on SAR volumes, decision timeliness, and any delays.
4. Review and document MLRO training — confirm role-specific training is up to date.
5. Strengthen compliance monitoring — add or enhance specific testing of SAR controls with clear escalation and tracking.
6. Address any MLRO conflicts of interest and record mitigations.

JFSC Key Self-Assessment Questions (use these directly in your review):

• Does the board have adequate oversight of SAR risk and timeliness of eSARs?
• Are your policies and procedures up to date, clear, and do they explain exactly how and when to raise an iSAR?
• Does your iSAR form and SAR register capture all required information under the Handbook?
• Is training on identifying and reporting suspicion tailored and delivered at the right frequency?
• Do staff understand tipping-off risks and are effective controls in place?
• Does the MLRO (and any deputy) have sufficient independence, authority, and support?
• Is your compliance monitoring of SAR controls robust enough to give the board confidence?

Suggested Timeline for Action

• This week / by mid-June: Read the full feedback paper and complete an initial gap analysis.
• By end of June / early July: Draft a time-bound action/remediation plan with clear owners and deadlines.
• Q3 2026: Implement priority enhancements and conduct follow-up testing.
• Ongoing: Embed improved MI and monitoring; retain full documentation of your review and actions.
• Remediation: Firms that received direct findings in this or previous examinations should already be working on formal remediation plans for their supervisor.

Bottom line:

• While many firms are already performing well, the JFSC has given clear, practical pointers on where controls can be strengthened. MLROs and compliance teams should treat this as a priority review item over the coming weeks.
• If you would like a ready-to-use gap analysis template, action plan tracker, or help tailoring this to your firm's specific circumstances, feel free to get in touch with the Comsure team – yes@comsuregroup.com

Sources –  

• Main JFSC News Announcement https://www.jerseyfsc.org/news-and-events/feedback-from-our-suspicious-activity-reporting-examination/
• 2025 SAR Examination Feedback Page https://www.jerseyfsc.org/industry/examinations/examination-findings-and-questionnaires/2025-suspicious-activity-reporting-examination-feedback/
• Full Feedback Paper (PDF – Essential Reading) https://www.jerseyfsc.org/media/vrtgwzqn/examination-feedback-suspicious-activity-reporting.pdf

This update is for information purposes and does not constitute legal or regulatory advice. Always refer to the original JFSC documents and seek appropriate professional advice where necessary.