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The JFSC - Estate agency to be questioned on employee AML/CFT/CPF training - COMPLY BY 23:59 on 30 June 2024.


THE JFSC are asking estate agents questions on AML/CFT/CPF training.

  1. During the second quarter of 2024, they will be carrying out a desk-based thematic examination of all estate agents.
  2. The JFSC will send out a questionnaire to all estate agents on the island on Wednesday 15 May, which they must complete by 23:59 on 30 June 2024.

The questionnaire will focus on estate agents’ anti-money laundering, terrorist financing and proliferation financing training for employees.

  1. The JFSC will assess how effectively the training meets the estate agent’s obligations as a supervised person, and whether the content of their training is effective in raising employee awareness and understanding of the estate agent’s relevant policies and procedures.
  2. Where responses to the questionnaire indicate that an estate agent may not be able to comply with all its statutory and regulatory requirements, the JFSC may carry out follow-up supervisory engagement.
    • This may include us agreeing on formal remediation plans with the estate agent or other supervisory action appropriate to the circumstances.
  3. The JFSC will publish feedback from its examination, explain the outcomes of the examination, and give examples of best practices.


  1. Supervised persons, including estate agents, must.
    • Take appropriate measures to raise employee awareness of relevant anti-money laundering, countering the financing of terrorism and countering proliferation financing policies, procedures and enactments.
    • Provide training which is specific to their business and relevant to the employees who complete it.
    • Establish and maintain procedures that monitor and evaluate the effectiveness of those policies and procedures and employees’ awareness and training.
  2. All supervised persons are required by the Money Laundering (Jersey) Order to ensure that employees whose duties include the provision of financial services:
  3. Are made aware of:
      1. The CDD, record-keeping, reporting and other policies and procedures for the purposes of preventing and detecting money laundering and the financing of terrorism
      2. The enactments in Jersey relating to money laundering and the financing of terrorism and any relevant Code of Practice
  4. Are provided, from time to time, with training in the recognition and handling of:
      1. Transactions carried out by or on behalf of any person who is or appears to be engaged in money laundering or the financing or terrorism
      2. Other conduct that indicates that a person is or appears to be engaged in money laundering or the financing of terrorism.
  5. The Order also sets out that training must involve, among other things, information on current money laundering techniques, methods and trends.
  6. The Anti-Money Laundering/Countering the Financing of Terrorism/Countering Proliferation Financing Handbook also sets out regulatory requirements in the Codes of Practice for relevant persons, including estate agents, in relation to screening, awareness and training of employees

The JFSC says:-

  1. The vigilance of well-trained employees is a critical element in preventing, detecting and reporting money laundering, terrorist financing and proliferation financing activity.
  2. That’s why we regularly assess supervised persons, including estate agents, and their employees’ awareness of money laundering, terrorist financing and proliferation financing risks, and the relevance and effectiveness of businesses’ training in this area.



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