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JFSC NPO Newsletter NO1 = 31 MARCH 2023


The JFSC have issued the first of a new quarterly newsletter, highlighting upcoming events, key contacts, and further reading for non-profit organisations.


  • Government of Jersey's Combatting Financial Crime Together event, where Sam Davison and Kate Rogers presented.
  • You can watch the video below.


Q1 = would this make the Jersey NPO Prescribed

Q1: If a Jersey NPO is a branch of an English charity, or only donates to an English charity which in turn sends funds to other jurisdictions, would this make the Jersey NPO Prescribed?

A2: No - If your NPO only pays to a registered charity in England who then in turns disburses the donations to other jurisdictions, your NPO would not be classed as a Prescribed NPO.

Q2: What is a Risk Appetite Statement and what should it include?

A2: Prescribed NPOs are required to:-

  • define and document their NPO's approach to diversion risk in a risk appetite statement (see section 17.3.1 NPO Handbook). Diversion is the principal way NPOs may be abused for terrorist financing.
  • The Glossary of the Handbook NPO Handbook Section 17.2 defines Diversion as
    • “Transactions by NPO Representatives or external parties such as associate NPOs that divert funds away from the NPO’s legitimately intended purposes to a terrorist, terrorist cell or terrorist organisation for them to benefit from, directly or indirectly”.
  • The purpose of the statement is to provide an overview of what risk the NPO is or is not willing to tolerate in undertaking its activities.
  • The statement doesn't need to be long, just appropriate and proportionate to the size and complexity of your NPO.
  • A risk appetite statement should confirm, at a minimum, that the Prescribed NPO will not tolerate diversion, nor parties that enable diversion.
  • Areas to consider include:
    • Are there jurisdictions, territories, or areas the NPO is comfortable to operate?
    • Where it has previous experience and is engaged with known associate NPOs. There may be other places where the NPO is unwilling to operate.
    • If the Prescribed NPO will avoid the use of certain payment methods (e.g., cash, pre-paid cards, hawala, mobile money, virtual assets etc.).
    • If working alongside certain associate NPOs falls outside the NPO’s risk appetite.
    • What contractual arrangements and terms it will be prepared to put in place working with an associate NPO, for example seeking undertakings of non-tolerance for diversion.
    • What types of donors it will accept funding from.
    • Who it will distribute benefits to and where.
    • Certain conflict levels which it will not tolerate, such as delivering aid in an active warzone.
  • Further details on the appropriate content of the statement can be found within the Handbook.


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