JFSC 2025 Suspicious Activity Reporting Examination Feedback Issued: 27 May 2026

As part of its 2025 thematic examination programme, the Jersey Financial Services Commission (JFSC)

• Assessed how well nine supervised persons complied with their legal and regulatory obligations relating to suspicious activity reporting (SAR).

The examination evaluated supervised persons' compliance with

• The Money Laundering (Jersey) Order 2008 and
• The relevant sections of the AML/CFT/CPF Handbook concerning suspicious activity reporting.

This thematic review was conducted in response to

• A Recommended Action in Jersey's 2024 MONEYVAL Mutual Evaluation Report, which identified the need to strengthen the identification and reporting of suspicious activity by supervised persons to the Financial Intelligence Unit, Jersey (FIU).

The JFSC's feedback paper provides:

• An overview of the examination and key findings
• Statistics detailing the examination results
• A summary of obligations where money laundering or terrorist financing is suspected
• A detailed table of findings, including examples of best practice
• Key questions to assist supervised persons in assessing their own systems and controls

Examination Findings

The JFSC grouped its findings under the following themes:

• Board oversight
• Policies and procedures
• SAR register and records
• Role of the Money Laundering Reporting Officer (MLRO)
• Training
• Compliance monitoring

Key Findings

Overall, the firms examined demonstrated a good level of compliance, with four out of the nine receiving no findings. Where deficiencies were identified, they primarily related to:

• Board oversight of the timeliness of reporting by the Money Laundering Reporting Officer (MLRO)
• Policies and procedures not updated to reflect current requirements (most common)
• Suspicious activity reports (SAR) register and records (most common)
• Role and independence of the MLRO (most common)
• Ongoing training of the MLRO
• Compliance monitoring of SAR-related systems and controls

Feedback

• All examined firms received feedback. Those with findings were required to submit a formal remediation plan to their supervisor, detailing the actions to be taken and the timescales for completion.

Next Steps

• The JFSC encourages all supervised persons to review this feedback paper and assess their own systems and controls, identifying and implementing any necessary enhancements.

Further information:

• Full feedback on suspicious activity reporting, News and Events
• Please read the full feedback on suspicious activity reporting.
• https://www.jerseyfsc.org/news-and-events/feedback-from-our-suspicious-activity-reporting-examination/
• https://www.jerseyfsc.org/industry/examinations/examination-findings-and-questionnaires/2025-suspicious-activity-reporting-examination-feedback/