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JFSC consultation and proposed revision to current Outsourcing Policy (OSP) and Guidance Notes.


Summary of proposed key changes:

  • All Supervised Persons [including Sch2 businesses eg estate agents, accountants and lawyers) must comply with the Revised OSP in accordance with the new consolidated AML/CFT Handbook
  • Where a Service Provider performs outsourced activity in the form of telecommunication services on behalf of a business, such outsourced activity is not caught
  • Specific guidance is provided where a service provider performs outsourced activity in the form of Cloud Services
  • Managed Trust Company Business is now exempt from the application of the Revised OSP
  • The provisions of and corresponding guidance within the Revised OSP have been amended to read more clearly and simply and to reflect our current regulatory framework

More detailed information on each key change is set out in the JFSC consultation.

Who will the Revised OSP impact?

  • The Revised OSP will impact any person to whom the provisions of the Revised OSP apply. The requirement for all Supervised Persons to comply with the Revised OSP represents a change of policy insofar as only regulated persons carrying on regulated business have had to comply with the current OSP and Guidance Notes to date.

Next steps

  • Close Wednesday 31 August 2022.
  • Following the JFSC consultation, we will publish feedback and issue a final form Revised OSP in October.
  • There will then be a three-month transition period for compliance with the Revised OSP – January 2023