Consultation on changes to the reliance and money laundering compliance officer regimes
Consultation on changes to the reliance and money laundering compliance officer regimes1 Executive summary
1.1 We are consulting on proposed updates to certain sections of the Handbook for the prevention and detection of money laundering, the countering of terrorist financing, and the countering of proliferation financing (the Handbook) predominantly to reflect changes made to the Money Laundering Order (Jersey) 2008 (MLO) in April 2026. These changes aim to reduce compliance costs on industry in respect of the role of the Money Laundering Compliance Officer (MLCO) and the reliance regime, while still managing risk proportionately.
1.2 For the purposes of this consultation, the reliance regime refers to the framework under Articles 16 and 16A of the MLO, including the conditions under which a supervised person may rely on identification measures applied by an obliged person (or external person in respect of group reliance), and the associated Codes of Practice and guidance.
1.3 Our intention is to simplify and modernise the requirements to introduce greater flexibility and reduce unnecessary operational burdens. Specifically, we are proposing targeted amendments to the Codes of Practice and related guidance to:
1.3.1 allow supervised persons not to appoint an MLCO in scenarios where it is appropriate with reference to their size and risk
1.3.2 provide flexibility by allowing the decoupling of the MLCO’s responsibility and operational compliance monitoring functions, including allowing support arrangements
1.3.3 enable practical reliance by providing a risk-based approach in line with recent changes to the MLO, in particular the removal of the mandatory testing requirements
1.4 These proposals form part of the wider Financial Services Competitiveness Programme. We continue to work closely with the Government of Jersey (GoJ) and industry to identify opportunities to improve the effectiveness and proportionality of the current frameworks while maintaining alignment with international standards. Our aim is to embed a risk-based and proportionate approach.