UPDATED JFSC AML/CFT/CPF HANDBOOK NOW EXPECTED 31 MAY 2026 - Immediate Actions to Take and Prioritise

On 27 November 2025, the JFSC has:-

• Outlined its responses to Consultation Paper No. 4 2025 in its  "Feedback on Enhancements to the AML/CFT/CPF Handbook,"
• Outlined its new rules on criminal background checks
• Issued a follow-on consultation on the topic of “complex structures"
• Deferred PEPs changes pending 2026 Government work/FCA guidance review (communicated first half of  2026).

It is now the intention to have an updated AML/CTF/CPF handbook, Effective on 31 May 2026.

Immediate Actions to Take and Prioritise

• Based on the above, Jersey-supervised persons should focus on actions related to ongoing engagement and preparation for upcoming changes.
• These documents address enhancements to criminal background checks (CRCs) for principals and key persons, and updates to the AML/CFT/CPF Handbook (including complex structures).

Prioritised Immediate Actions

1. Highest Priority: Review and Respond to the Open Consultation on Complex Structures (if applicable) https://www.jerseyfsc.org/industry/consultations/follow-on-consultation-amlcftcpf-handbook-enhancements-complex-structures/
• The "follow-on-consultation-aml-cft-cpf-handbook-enhancements-complex-structures.pdf" is an active consultation (No. 8 2025) seeking feedback on revised proposals for handling complex structures in the AML/CFT/CPF Handbook.
• This follows industry input from the prior consultation and splits guidance into standard customer due diligence (CDD) for non-high-risk structures (Section 4) and enhanced CDD for high-risk opaque structures (Section 7).
• Action: Review the draft documents and proposed changes (outlined in Sections 4 and 7 of the consultation). If your organisation deals with complex structures (e.g., in funds, trusts, or multi-layered entities), consider submitting comments directly to the JFSC Policy team (policy@jerseyfsc.org) or via Jersey Finance Limited (JFL) coordinator Tim Hart (timothy.hart@jerseyfinance.je). Responses are non-confidential unless specified, and JFL will collate anonymised industry input.
• Why prioritise? The deadline is approaching (about 2 months away), and input could shape the final guidance. If you miss it, you lose the chance to influence proportionality and practicality. Contact the team for support if needed.
• Timeline: Start reviewing immediately; submit by the deadline below.
2. Review Feedback Papers and Assess Internal Impact
• Read the following  two documents in full to understand finalised policy positions:
• https://www.jerseyfsc.org/media/0rpnaady/feedback-on-enhancements-to-criminal-background-checks.pdf
1. Confirms removal of the three-year rolling Criminal Records or Background Checks refresh; shifts responsibility to Supervised Persons to collect/maintain CRCs (e.g., DBS checks or equivalents) for principal persons (PPs) and key persons (KPs) at application, on changes, and as needed.
• https://www.jerseyfsc.org/media/bzlk5pio/feedback-on-enhancements-to-the-aml-cft-cpf-handbook.pdf
1. Proceeds with most enhancements (e.g., EDD for PEPs and complex structures, periodic reviews, beneficial ownership/control, sanctions, and sector-specific guidance for DNFBPs/VASPs), but defers complex structures to the follow-on consultation. Includes support for a standalone Prescribed NPO CFT Handbook.
• Action: Conduct an internal gap analysis to identify how these changes affect your policies, procedures, systems, and training (e.g., updating CDD processes, sanctions screening for indirect links, or CRC collection). Involve compliance teams, MLRO/MLCO, and senior management.
• Why now? Although implementation is scheduled for 2026, early assessment allows time for updates without last-minute rushes. Use the JFSC-provided tools, such as mapping documents and webinars (listed as planned support).
3. Prepare for Implementation and Monitor Updates
• Action: Begin planning resource allocation for system/process updates, staff training, and record-keeping enhancements. For CRCs, ensure mechanisms to obtain certified copies within six months of relevant events. For Handbook changes, focus on risk-based approaches (e.g., proportionality in EDD for PEPs/close associates and complex structures).
• Lower priority but start soon: If you're a Prescribed NPO, note the planned standalone CFT Handbook. Contact JFSC teams for clarifications (authorisations@jerseyfsc.org for CRCs; policy@jerseyfsc.org for AML/CFT/CPF).

If you're not directly affected (e.g., not a supervised person), you don't need to do anything else besides staying informed via JFSC channels.

Key Dates for Your Compliance and Action Diary

Add these to track consultations, publications, and implementations. All dates are in 2025–2026; I've included context for each.

These dates are based on JFSC's responses to industry feedback, which emphasised the need for sufficient preparation time—no earlier deadlines (e.g., past consultations closed in January–September 2025). Monitor the JFSC website for any updates or extensions. If you need clarification, use the provided contacts.

Handbook for financial services business, together with a tracked change version.  Handbook (tracked changes) Handbook (clean version)

• http://www.jerseyfsc.org/media/gtmjnzvq/tracked-handbook-november-2025.pdf
• http://www.jerseyfsc.org/media/wr5prwn5/clean-handbook-november-2025.pdf

Matrix mapping the COP of the existing Handbook to the new version. Matrix mapping

http://www.jerseyfsc.org/media/dr3dph2e/handbook-mapping-november-2025.xlsx