MONEYVAL didn’t pick a winner — so who is right on Channel Island fines?

The Guernsey Press article published today,

• “GFSC backs higher fines than Jersey for financial offences,” is the reason for this analysis.

• https://guernseypress.com/news/2026/09/27/gfsc-backs-higher-fines-than-jersey-for-financial-offences

The article reports that the Guernsey Financial Services Commission sees no case for cutting its £400,000 maximum civil fine for individuals, even as Jersey has decided to lower its equivalent cap from £400,000 to £250,000 after industry argued the higher figure had an “excessive dissuasive effect” on senior compliance recruitment.

• A GFSC spokesman said the £400,000 ceiling was set by the States in 2017, was not criticised in Guernsey’s MONEYVAL report of February 2025, and has never been collected in full for any individual.

• That contrast is not a sideshow. Both islands are international finance centres whose reputations rest on demonstrating FATF-equivalent standards. Fine maxima sit inside a larger test: whether sanctions are effective, proportionate, and dissuasive.

Two strong MONEYVAL reports, not the same scorecard

• Jersey’s Fifth Round Mutual Evaluation Report was published on 24 July 2024 after an onsite visit in autumn 2023.

  • Official summaries record one High effectiveness rating (Immediate Outcome 1: risk, policy, and coordination — a result described as rare globally), six Substantial ratings and four Moderate ratings, including supervision, preventive measures, financial intelligence, and money-laundering investigation and prosecution.

  • Technical compliance was Compliant or Largely Compliant on 39 of the 40 FATF Recommendations. No “fundamental improvements” were required.

• Guernsey’s report was published on 10 February 2025 after an onsite visit in April 2024.

  • The Bailiwick received pass ratings (High or Substantial) on six of eleven Immediate Outcomes and was placed in regular follow-up. It is one of a very small group of jurisdictions to receive more than one High rating — for terrorist-financing sanctions and NPO oversight (IO.10) and proliferation-financing sanctions (IO.11). Technical compliance was Compliant or Largely Compliant on all 40 Recommendations.

  • The weakest effectiveness mark was money-laundering investigation and prosecution, where fundamental improvements were said to be needed to match the jurisdiction’s IFC risk profile.

  • Supervision, preventive measures/SAR quality, use of FIU products and confiscation were also flagged for further work.

• In headline terms:

  • Jersey scored higher on effectiveness passes and stood out in national risk understanding.

  • Guernsey led on complete technical compliance and sanctions effectiveness. Neither result threatened grey-listing.

The fine that MONEYVAL did not criticise

• FATF Recommendation 35 and the effectiveness methodology ask whether available sanctions are used and whether they can deter serious misconduct. Guernsey’s individual maximum of £400,000 appears in the GFSC’s published bandings (Band 4).

• The Commission told the Press that only three people were initially assessed at £250,000; two of those settled for less; and no individual has paid more than £250,000.

• The 2025 MONEYVAL report did not criticise the statutory maximum.

• Jersey’s government consultation on civil financial penalties for natural persons explicitly cited an “excessive dissuasive effect” on people taking key-person and senior management roles.

  • Option A, which cut Band 3 from £400,000 to £250,000 (with further reductions or disapplication for some lower bands for key persons and SMFs), was preferred. Officials argued the revised caps would remain FATF-compliant.

• To date Jersey has been far more cautious than Guernsey about public individual civil fines.

• Industry commentary has drawn the same contrast:

  • Guernsey has been quicker to name individuals and attach personal financial consequences;

  • Jersey has tended to focus on corporate penalties and remediation.

What this means

• Both islands face the same structural risk: sophisticated trust, fund, banking, and insurance business exposed mainly to external money-laundering threats.

• Personal liability for senior officers is one tool for concentrating minds on systems and culture.

  • Guernsey is treating the higher ceiling as a signal of seriousness and as alignment with European expectations, while applying it sparingly.

  • Jersey is treating the same ceiling as a recruitment problem and lowering it while keeping higher corporate maxima in place.

• Neither choice is automatically “non-compliant.” MONEYVAL judges’ outcomes: supervision that matches risk, the actual use of powers, the quality of SARs, the exploitation of intelligence, investigations that fit the IFC profile, and confiscations. Fine maxima are only one lever.

• The GFSC’s other point in the Press piece is the one that matters for both islands.

• Overseas counterparties — including processes such as Guernsey’s application to the US National Association of Insurance Commissioners — care whether a regulator can enforce and deter.

• Reputation as a clean, cooperative finance centre is an economic asset. Jersey’s consultation and Guernsey’s defence of its maxima are both attempts to protect that asset.

• The next MONEYVAL follow-up cycles will show which calibration better supports the operational improvements both reports still demanded.

End

Sources

Trigger article

https://guernseypress.com/news/2026/09/27/gfsc-backs-higher-fines-than-jersey-for-financial-offences

Guernsey MONEYVAL

https://www.gov.gg/bailiwick-moneyval-evaluation

https://www.gov.gg/CHttpHandler.ashx?id=186514&p=0

https://www.gfsc.gg/news/commission-welcomes-guernseys-positive-moneyval-report

https://www.guernseyfinance.com/industry-resources/news/2025/guernsey-receives-positive-moneyval-evaluation

https://www.bailiwickexpress.com/news-ge/guernsey-among-leaders-in-fight-against-dirty-money/

https://www.lexology.com/library/detail.aspx?g=246a9313-f027-4012-8a28-16eef8c47d2c

https://iclg.com/news/22249-relief-for-guernsey-following-financial-crime-report/

https://eucrim.eu/news/moneyval-fifth-round-evaluation-report-on-guernsey/pdf/

Jersey MONEYVAL

https://www.gov.je/Industry/Finance/FinancialCrime/Pages/FATFAndMoneyVal.aspx

https://www.jerseyfsc.org/industry/international-co-operation/international-assessments/moneyval/2024-moneyval-evaluation

https://www.gov.je/News/2024/pages/jersey%E2%80%99sstrengthincombattingfinancialcrimeisrecognised.aspx

https://www.jerseyfinance.com/insights/first-for-finance-16th-edition-affirmation-of-jerseys-high-international-standards/

https://kpmg.com/dp/en/home/insights/2024/07/jersey-top-performer-in-tackling-financial-crime.html

https://eucrim.eu/news/moneyval-fifth-round-evaluation-report-on-jersey

https://investment-international.com/News/moneyval-report-concludes-jersey-performs-well-against-international-aml-standards/

Jersey fine-cap consultation/response https://www.gov.je/SiteCollectionDocuments/Industry%20and%20finance/Consultation%20document%20on%20civil%20financial%20penalties%20regime%20and%20natural%20persons.pdf

https://www.gov.je/SiteCollectionDocuments/Industry%20and%20finance/Civil%20Financial%20Penalties%20Natural%20Persons%20Consultation%20Response%20Paper.pdf

https://www.jerseyfsc.org/industry/guidance-and-policy/civil-financial-penalties-on-natural-persons

https://www.jerseylaw.je/laws/current/PDFs/RO_71_2015.pdf

GFSC penalty bands/enforcement

https://www.gfsc.gg/sites/default/files/uploads/Discretionary%20Financial%20Penalties%20-%20Schedule.pdf

https://www.gfsc.gg/commission/enforcement/enforcement-powers

Industry comparison pieces

https://www.comsuregroup.com/news/jersey-vs-guernsey-a-tale-of-two-island-regulators-on-financial-penalties/

https://www.comsuregroup.com/news/muratti-guernsey-wins-on-the-pitch-and-in-regulatory-gfscvjfsc-enforcement/

https://www.ocorian.com/knowledge-hub/insights/gfsc-and-jfsc-public-statements-key-lessons-recent-enforcement-actions

https://www.spencer-west.com/news/navigating-the-gfscs-evolving-enforcement-landscape-key-takeaways-for-financial-services-businesses/