The regulatory fine lists your name, but Jersey has not used it. Others have.

The regulatory fine lists your name, but Jersey has not used it. Others have.

This note concerns personal risk for Jersey-regulated individuals, not a new Jersey law.

• The JFSC already has the power to fine a principal person, key person or senior manager. It has not been used. Guernsey has.

• The UAE has just fined an MLRO in his own name for not doing the job, without a money-laundering charge.

• Singapore and the United States show the same direction in different forms: bans and an older civil penalty that still turned on wilful failure. (discussed below)

The conclusion is narrow.

• Jersey has not announced that individual fines are about to start. A lower maximum does not retire the power.

• With Guernsey using it, and with MONEYVAL already criticising Jersey’s modest sanctions, an individual civil penalty is available now and harder to treat as a permanent exception the longer the public record stays at zero.

Jersey-regulated individuals should not take comfort from the island’s record.

• The power has existed since 2018/19.

• On the public record, it has not been used up to mid-2026.

That is an enforcement choice.

• The ceiling is being cut from £400,000 to £250,000 after a consultation which argued that the higher figure had an excessive dissuasive effect on people taking senior compliance roles.

• A lower maximum is not a promise that the power will stay unused. MONEYVAL’s July 2024 report already said Jersey relies on remediation, with sanctions too modest for the breaches found.

Guernsey is the nearest evidence of what the power looks like in use.

• The GFSC has refused to follow Jersey’s cut. A spokesman said there was no reason to lower Guernsey’s £400,000 maximum and pointed to the Bailiwick’s MONEYVAL report of February 2025, which did not criticise that ceiling.

• The same spokesman said the Commission has never collected more than £250,000 from an individual: two notional fines above that level were reduced on settlement. Guernsey fines individuals repeatedly alongside the firm. Jersey does not. A compliance officer who treats the two regimes as interchangeable is misreading the public record.

The sharper examples are outside the Channel Islands, and they do not all work the same way. Read more on the UAE, Singapore and the United States.

UAE, Singapore and the United States - Speed read

• On 24 June 2026, the UAE Central Bank fined a foreign bank branch AED 20 million and its Head of Compliance and MLRO AED 300,000 for not performing the role. No laundering charge. The notice cites the Central Bank law, not Decree-Law 10.

• The same regulator fined and banned a branch manager in May 2025, under Article 137, before Decree-Law 10 was in force.

• Singapore’s recent individual actions are prohibition orders, some after convictions. The US Haider case was a 2014 wilful-failure penalty, later cut from US$1 million to US$250,000.

• MONEYVAL told Jersey in July 2024 that sanctions were too modest for the breaches found. The individual fine is the obvious unused tool.

UAE

 1. On 24 June 2026, the Central Bank of the UAE fined a branch of a foreign bank AED 20 million for significant, repeated failures in its anti-money laundering, counter-terrorist financing, illegal organisations and sanctions framework.

a. In the same action, it fined the branch’s Head of Compliance and Money Laundering Reporting Officer AED 300,000, in his own name, for failing to fulfil the responsibilities of his position. The bank was not named.

                                                              i.      No money-laundering charge was announced.

b. The notice cites the Central Bank law — Decretal Federal Law No. 14 of 2018, including Article 137 — not Federal Decree-Law No. 10 of 2025.

                                                              i.      This was not the first use.

c. On 20 May 2025, the same regulator fined an exchange house AED 200 million and a branch manager AED 500,000 and banned him from any position in a licensed UAE financial institution, expressly under Article 137. Decree-Law 10 was not yet in force.

2. The June 2026 case moves the target from a branch manager at an exchange house to a Head of Compliance and MLRO at a foreign bank branch.

a. AED 300,000 is modest next to AED 20 million on the branch and below the May 2025 individual fine. The point is the name on the notice, not the amount.

b. Decree-Law 10 should not be briefed as the basis of that fine. It was issued on 30 September 2025, published in Official Gazette No. 808, and took effect on 14 October 2025.

c. It adds proliferation financing, raises corporate penalties, and deepens personal criminal liability for managers.

3. White & Case records liability where a manager had actual knowledge of a principal offence, or where a principal offence occurred because they breached their employment duties. Other commentary describes a lower bar: knowledge, consent or connivance, gross negligence, or a failure to supervise, with knowledge inferred from objective circumstances. The Arabic text prevails, and the commentaries do not agree. That is a criminal-statute change. It is not what the Central Bank cited on 24 June.

SINGAPORE

4. Singapore shows bans rather than personal fines.

5. On 4 July 2025, MAS

a. Imposed composition penalties of S$27.45 million on nine financial institutions for AML/CFT breaches linked to the August 2023 case.

b. It also issued prohibition orders of three to six years against four people at Blue Ocean Invest, with effect from 1 August 2025, including six years for the CEO and executive director.

c. Reporting at the time put the wider individual actions, including reprimands, at 18 people. Not all 18 were prohibition orders.

6. On 17 March 2026, MAS

a. Issued a 16-year prohibition order against Wang Qiming, formerly of Citibank, after convictions for forgery, money laundering and obstructing the course of justice, and a seven-year order against Liu Kai, formerly of Julius Baer, after a conviction for using a forged document. Those last two are fitness bans after criminal findings, not fines for a weak framework. Singapore’s mutual evaluation, published on 6 May 2026, identifies MAS supervision as a strength and notes that enforcement actions remain relatively low. Do not cite it as an endorsement of the 2025 individual actions unless a specific paragraph is quoted.

USA

7. The United States is the older precedent, and it is narrower than it is often briefed.

8. On 18 December 2014, FinCEN

a. Assessed US$1 million against Thomas E. Haider, former chief compliance officer of MoneyGram, for failing to ensure an effective AML programme and to file suspicious activity reports. The case settled in May 2017 for US$250,000.00, with a three-year bar on performing a compliance function for a money transmitter and with admissions. It turned on wilful failures: what he knew or had reason to suspect, and what he failed to stop. It is not a strict-liability precedent.

The timely point for Jersey is the gap.

• Guernsey has already fined the individual.

• The UAE has fined an MLRO for not doing the job, without a laundering charge.

• MONEYVAL has already told Jersey that its sanctions are too modest for the breaches found.

• A cut in the maximum, adopted because the old ceiling was said to deter people from taking senior compliance roles, does not close that criticism. It lowers the number. It leaves the power in place.

• Jersey-regulated principal persons, MLROs and compliance officers should treat an individual civil penalty as available now, unused so far, and harder to defend as a permanent exception the longer the public record stays at zero.

CLOSE

• Do not interpret this brief as “Jersey has announced it will start fining individuals”. It has not.

Sources

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

• https://www.coe.int/en/web/moneyval/-/moneyval-acknowledges-jersey-s-progress-in-improving-measures-to-combat-money-laundering-and-financing-of-terrorism

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

• https://www.khaleejtimes.com/uae/uae-imposes-dh20-million-fine-on-foreign-bank-for-repeated-violations

• https://gulftime.ae/cbuae-imposes-a-financial-penalty-of-aed20-million-on-branch-of-foreign-bank/

• https://www.zawya.com/en/press-release/government-news/cbuae-imposes-a-financial-penalty-of-aed-20000000-on-a-branch-of-a-foreign-bank-332191

• https://www.thenationalnews.com/business/2026/06/24/uae-central-bank-fines-foreign-bank-dh20m-for-breaching-money-laundering-rules/

• https://www.arabianbusiness.com/finance/banking/uae-central-bank-fines-foreign-bank-anti-money-laundering-failures

• https://www.globalinvestigations.blog/uncategorized/uae-central-bank-fines-foreign-bank-and-compliance-officer-for-money-laundering-violations/

• https://www.centralbank.ae/media/u1yfjiyi/cbuae-imposes-a-financial-sanction-of-aed-200-million-on-an-exchange-house-en.pdf

• https://www.khaleejtimes.com/business/finance/uae-fines-exchange-house-for-anti-money-laundering-law-breach

• https://www.zawya.com/en/press-release/government-news/cbuae-imposes-a-financial-sanction-of-aed-200mln-on-an-exchange-house-rsxaixti

• https://rulebook.centralbank.ae/en/rulebook/federal-decree-law-no-10-2025-regarding-anti-money-laundering-and-combating-financing

• https://uaelegislation.gov.ae/en/legislations/3314

• https://www.whitecase.com/insight-alert/uae-enacts-new-aml-law-what-are-key-changes-and-what-does-mean-your-business

• https://www.mondaq.com/money-laundering/1765866/uaes-new-aml-law-enforcement-evidence-and-senior-management-liability

• https://globallawexperts.com/federal-decree-law-no-10-of-2025-key-changes-and-new-aml-cft-regulations-in-the-uae/

• https://www.corporatecomplianceinsights.com/day-my-job-description-changed-compliance-personal-liability/

• https://www.mas.gov.sg/regulation/enforcement/enforcement-actions/2025/mas-takes-regulatory-actions-against-9-financial-institutions-for-aml-related-breaches

• https://www.channelnewsasia.com/singapore/mas-27-million-penalty-banks-credit-suisse-uob-ubs-money-laundering-case-5220456

• https://www.mas.gov.sg/regulation/enforcement/enforcement-actions/2026/mas-issues-prohibition-orders-against-former-relationship-managers-wang-qiming-and-liu-kai

• https://www.channelnewsasia.com/singapore/mas-prohibition-order-bank-relationship-manager-wang-qiming-liu-kai-5998521

• https://www.fatf-gafi.org/en/publications/Mutualevaluations/mer-singapore-2026.html

• https://www.mha.gov.sg/media-room/newsroom/singapore-has-a-robust-framework-for-combatting-financial-crime-according-to-international-body/

• https://www.fincen.gov/news/news-releases/fincen-assesses-1-million-penalty-and-seeks-bar-former-moneygram-executive

• https://www.fincen.gov/news/news-releases/fincen-and-manhattan-us-attorney-announce-settlement-former-moneygram-executive

• https://www.justice.gov/usao-sdny/pr/manhattan-us-attorney-sues-thomas-e-haider-former-chief-compliance-officer-moneygram

• https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32018L1673

• https://www.springlex.eu/en/packages/aml/aml6-directive/article-6/

• https://www.springlex.eu/en/packages/aml/amlr-regulation/article-11/

The Guernsey Press piece is subscriber-only. The “no Jersey individual fine” line rests on the Comsure note to mid-2026, not on a JFSC register extract. I have not rechecked that every link still resolves.