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JFSC Thematic programme examinations in Q2+3 2021

  1. In November 2020, the JFSC  published its programme of thematic examinations for early 2021.
  2. The JFSC is now publishing its thematic programme for the remainder of the year 2021.
The JFSC  Supervision Examination Unit (SEU) will undertake
  1. TWO further thematic examinations in Q2 and Q3 2021.
    • Customer risk assessments
    • Monitoring of customer relationships and transactions
The JFSC  Pooled Supervision Unit will undertake
  • Visits on the legal sector

These are discussed further below:-

The JFSC  Supervision Examination Unit (SEU) will undertake

Customer risk assessments

  1. The first of these will focus on customer risk assessments; this results from many findings that continue to be identified through the JFSC  examination programme.
  2. It also links to the National Risk Assessment (NRA) recommendations, particularly the Trust and Company Services Provider chapter.
  3. The examination’s primary focus will be on
    • Testing how well businesses obtain information for assessing the risks of money laundering and the financing of terrorism,
    • Establishing how well that information is evaluated once gathered.
Monitoring of customer relationships and transactions
  1. In Q3, the SEU will focus on the ongoing monitoring of customer relationships and transactions.
  2. This examination will
    • Test the systems and controls in place that enable businesses to scrutinise transactions and ensure they are consistent with their knowledge of the customer.
    • It will also look at how businesses keep documents, data or information up to date and relevant by undertaking reviews.
  3. These examinations will consist of two elements.
    • A questionnaire will be issued to a number of organisations,
    • With more in-depth examinations taking place at selected businesses.
Legal sector
  1. The JFSC  Pooled Supervision Unit will also undertake a thematic examination of the Legal Sector in Q2 and Q3 of 2021.
  2. The scope of the examination will include:
    • Client risk assessments,
    • Use of client accounts,
    • Suspicious activity reports,
    • Employee training and
    • Knowledge and the effectiveness of compliance systems and controls;
  3. All of which are areas highlighted in the NRA.
  4. The JFSC  will be hosting a webinar on the JFSC  approach to examinations on Wednesday, 24 March at 14:00.


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