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JFSC to REVISE its OUTSOURCING POLICY – this IMPACTS all SUPERVISED PERSONS [estate agents, accounts, lawyers etc.]


The JFSC has issued a consultation that proposes changes to the current Outsourcing Policy (OSP) and Guidance Notes.

The big change is

  1. All Supervised Persons must comply with the Revised OSP per the new consolidated AML/CFT Handbook

other changes:

  1. Where a Service Provider performs outsourced activity in the form of telecommunication services on behalf of a business, such outsourced activity is not caught
  2. Specific guidance is provided where a service provider performs outsourced activity in the form of Cloud Services
  3. Managed Trust Company Business is now exempt from the application of the Revised OSP
  4. The provisions of and corresponding guidance within the Revised OSP have been amended to read more clearly and to reflect the JFSC's current regulatory framework

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


A working group was established between March and April 2022 to review the draft Revised OSP before going out for a more comprehensive public consultation.

It included representatives from various sectors (Banking, TCB, FSB, Legal and Digital).

  1. The collective feedback of the working group and the JFSC  responses are included in the consultation.
  2. The JFSC is now asking for your feedback on the revised OSP.

Who will the Revised OSP impact?

  1. All Supervised Persons
  2. The requirement for all Supervised Persons to comply with the Revised OSP represents a policy change insofar as only regulated persons carrying on regulated business have had to comply with the current OSP and Guidance Notes to date.

Next steps

  1. The JFSC  encourage you to read The JFSC  consultation and respond byWednesday,31 August 2022.
  2. Following The JFSC  consultation, The JFSC  will publish feedback and issue a final Revised OSP in October.
  3. There will be a three-month transition period for compliance with the Revised OSP.

SOURCE JFSC -revised-outsourcing-policy/