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JFSC AML/CFT/CPF Key Milestones and Implementation Plan to MAY 31 2026

04/12/2025

Executive Summary

  • This posting summarises the Jersey Financial Services Commission (JFSC) AML/CFT/CPF enhancement programme, including key milestones from November 2025 to May 2026, significant changes, management actions, risks, and next steps.
  • The purpose is to ensure timely compliance and readiness for the effective date of 31 May 2026.

Key Milestones

27 November 2025:

  • Publication of feedback paper, follow-on consultation on complex structures, enhanced AML/CFT/CPF Handbook (draft), prescribed NPO CFT Handbook, and mapping document.

12 February 2026:

  • The feedback period for the consultation on complex structures closes.

26 March 2026:

  • Publication of feedback on complex structures, CP, and the updated, enhanced AML/CFT/CPF Handbook.

31 May 2026:

  • Effective date for the AML/CFT/CPF Handbook, including
    • Complex structures and
    • Criminal background checks (CBC).

Summary of Changes

  • Enhanced AML/CFT/CPF Handbook with usability improvements and clarifications.
  • New EDD Codes of Practice for complex structures.
  • Dedicated Prescribed NPO CFT Handbook with mapping guidance.
  • Criminal Background Check (CBC) requirements deferred to 31 May 2026; removal of 3-year rolling refresh.

Next Steps

  • Confirm internal milestone plan aligned to JFSC dates (26 Mar and 31 May 2026).
  • Approve CBC policy changes and delegate responsibilities for record collection.
  • Update handbooks, checklists, and templates using JFSC mapping documents.
  • Communicate changes to staff and third-party providers; deliver training.
  • Please run a dry-run audit in May 2026 to demonstrate readiness.

Management Actions

  • Assign Board-level sponsor and implementation lead for May 2026 readiness.
  • Update AML/CFT/CPF policies and procedures (EDD, complex structures, CBC) by 31 May 2026.
  • Conduct gap analysis against the November 2025 feedback and complex structures CP.
  • Schedule staff training in April–May 2026 on revised Handbook sections.
  • Ensure systems reflect new EDD triggers and CBC documentation requirements.

Risks if Not Implemented

  • Regulatory risk: Non-compliance could lead to findings in JFSC reviews.
  • Operational risk: Misaligned procedures and weak documentation.
  • Reputational risk: Failure to meet MONEYVAL-driven enhancements.

Key Source Links

JERSEY MONEY LAUNDERING CONSULTATION

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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.  

news disclaimer -

As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.