JFSC Bitesize feedback on targeted financial sanctions (Sept 2026)

The JFSC has published single-page Bitesize feedback on targeted financial sanctions, so firms can quickly see the findings and decide what action they may need to take.

In Q2 2026, the JFSC assessed how well 14 supervised persons across all industry sectors had implemented effective systems and controls to identify, manage, and report targeted financial sanctions risks.

The observations cover: ways compliance may be achieved

• Areas for improvement

• Key questions to consider

The feedback is designed to help you review your current approach and support effective compliance.

Focus examination: targeted financial sanctions

Ways compliance may be achieved:

• Well-documented sanctions screening processes, with clear methods for identifying, investigating and resolving potential matches, and comprehensive records showing the reasons for discounting alerts.

• Effective governance and oversight, supported by sanctions-specific risk assessments, risk appetite, management information and independent control testing.

• Clear, practical policies and procedures to support consistent identification, escalation and management of sanctions risks, reflecting operational practice.

Areas for improvement identified by the JFSC

• In some cases there was no assessment of how effective the screening arrangements were, which limits assurance over the adequacy of controls.

• Operational screening carried out by third parties was not always treated as outsourcing, which can lead to inadequate oversight, challenge and assurance.

• Screening of all associated parties and transaction counterparties was not always consistent, and arrangements for ongoing monitoring and periodic re-screening were limited or missing.

Key questions to consider

• Do you screen transaction counterparties, even if they are not your customer — that is, the person, company or entity on the other side of a transaction? You should have sufficient information to conduct proportionate sanctions screening.

• What controls do you have to make sure that funds or economic resources are not made available, directly or indirectly, to designated persons? Even if funds are sent through another regulated service provider, you still need to understand and manage the risks for the whole transaction.

• Is the discounting of potential sanctions supported by a clear, documented rationale, so that an independent third party could review and understand those decisions?

What’s next?

• Following the examinations, the JFSC will review and update its sanctions guidance.

• It has worked with the Jersey Sanctions Implementation Unit, which has updated its general sanctions guidance to include more on sanctions compliance reporting.

• The JFSC will also carry out two sets of focus examinations in 2027 and will publish the themes in advance.

Source: Jersey Financial Services Commission — Bitesize feedback, Focus examination: targeted financial sanctions (Q2 2026).

Read the JFSC Bitesize feedback here:
https://www.jerseyfsc.org/media/dqrcjaea/bitesize-feedback-focus-examination-targeted-financial-sanctions.pdf

News page:
https://www.jerseyfsc.org/news-and-events/read-our-bitesize-feedback-on-targeted-financial-sanctions/