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JFSC Company Registrar report - 1 October to 31 December and annual reflection for 2023. [highlights]


The following shows some highlights from the Feb 2024 publication. titled:-

  • Registrar of Companies report Registry Supervision inspection programme 2023 –
    • Quarterly feedback paper – 1 October to 31 December and
    • Annual reflection for 2023.

Summary of Key Findings for 2023

Findings show no systemic issues of concern, and most discrepancies are minor.

The most common inaccuracies found during our 2023 visits were:

1. A Failure to disclose the individuals who control a corporate trustee if not JFSC regulated.

2. Structure charts that need to clearly outline the ownership structure or provide sufficient details about the individuals or entities with significant ownership interests and control.

3. Difficulties associated with recording joint ownership of shares correctly.

4. Inadequate records and documentation related to address and identity verification.

5. Failure to provide translation documentation for foreign due diligence documentation.

6. Statutory registers containing inaccurate or outdated information.

Other findings of the 2,630 entities inspected during 2023:
  1. 460 entities did not initially provide evidence that statutory requirements to maintain registers were met.
  2. In all cases, the JFSC could authenticate the data held on the central register after further investigation.

JFSC X6 Good practice (a summary of findings from the four quarters of 2023)

  1. The JFSC has found that entities that keep up-to-date due diligence documentation with the registers tend to file the correct identification data.
    1. This leads to middle names, aliases, and maiden names being correct.
    1. In some cases, although registers held at the entity’s registered office were up to date, the JFSC found that the central record at the JFSC was not.
  2. JFSC Registry supervision examiners have observed that where entities are more effective in filing obligations, they regularly check the statutory registers against entity records.
  3. Good practice involves developing a comprehensive pre-inspection readiness plan.
    1. A readiness plan ensures that entities are well-prepared, reducing the risk of oversights and streamlining the inspection process.
  4. TCSPs with comprehensive documentation of trust structures, ownership, and control information tend to have fewer findings.
    1. For example, maintaining a detailed structure chart showing the individuals or entities with significant control or interests, including percentage ownership, helps demonstrate commitment to transparency and regulatory compliance and facilitates the inspection.
  5. Most TCSPs could identify the trustees, beneficiaries (vested/non-vested), settlors and protectors and accurately disclose their roles and powers.
  6. The myParties function within the myRegistry platform should be utilised as this enables users to submit more accurate information.
    1. The JFSC notes from our investigations that human error with data inputting is where most errors occur.
    1. Using the myParties feature enables users to enter the details once and then select it from their address book in future. The efficiency comes from only keying the information once and then applying it across other entities in your portfolio.

The feature provides several benefits, these include:

    1. Allowing users to create a library of regularly used associated parties.
    2. Reducing the time taken for a customer to complete myRegistry submissions –incorporations/registrations, annual confirmations and update associated parties.
    3. Improving the quality of data entered in myRegistry.

Entities are also reminded of the requirements of international standards to have a nexus to the island and the importance of the registered office.

    1. The JFSC draws your attention to the updated guidance on our websites on the registered office requirements and the steps to be taken when changing or objecting to a registered office.

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