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

08/07/2022

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
JERSEY

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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.