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  • Your feedback wanted: reliance and money laundering compliance officer regimes
Industry update 07 July 2026
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Your feedback wanted: reliance and money laundering compliance officer regimes

We're seeking feedback on proposed updates to our Handbook for the prevention and detection of money laundering, the countering of terrorist financing and the countering of proliferation financing.

The proposed changes reflect recent updates to the Money Laundering (Jersey) Order 2008 and aim to make requirements more flexible and proportionate while maintaining effective safeguards against financial crime. They also support the Financial Services Competitiveness Programme, a joint initiative between the Government of Jersey, the JFSC and Jersey Finance.

The consultation focuses on two areas:

  • the money laundering compliance officer framework
  • the reliance framework used for customer due diligence

Read the full consultation on changes to the reliance and money laundering compliance officer (MLCO) regimes and submit your feedback online by 5:00pm on Tuesday 18 August.

Summary of proposals

Money laundering compliance officer framework

  • introducing requirements for firms that elect to operate without appointing an MLCO
  • introducing guidance to help firms assess whether an MLCO is required
  • introducing guidance covering situations where an MLCO is supported by other suitably skilled persons, including the use of group or external specialists

Reliance framework

  • removing the obligations and guidance on mandatory testing
  • introducing the requirement for firms to evidence that they have taken ‘adequate steps’ based on an assessment of risk to satisfy themselves that evidence of identity can be obtained from an obliged person without request
  • introducing guidance on the new requirement to obtain updated written assurances
  • clarifying the requirements to review the appropriateness of continuing to rely on an obliged person for other customer relationships following the cessation of a reliance relationship, and introducing supporting guidance

Overall, the proposals aim to reduce unnecessary operational burden, improve clarity and maintain strong protections against financial crime.

Next steps

The consultation closes at 5:00pm on Tuesday 18 August 2026. We encourage you to review the proposals and share your feedback.

If you have any questions about the consultation, please email policy@jerseyfsc.org. 

Join our drop-in sessions

As part of the consultation process, we'll be hosting two drop-in sessions at the Old Magistrates Court on:

  • Monday 27 July 2026 at 12:00pm – 1:00pm
  • Wednesday 29 July 2026 at 12:00pm – 1:00pm

These sessions will provide an opportunity for you to discuss the proposals and ask questions before the consultation closes.

Register through Eventbrite to attend.   

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