Jersey National Risk Assessment

The Government of Jersey has published its updated Terrorist Financing National Risk Assessment  (“TF NRA”). The assessment concludes that the risk of Jersey being used as a conduit for TF remains medium-low.

The 2023 TF NRA builds on, and provides a summary of actions taken since the previous TF NRA published in April 2021 (2021 TF NRA).

The 2021 TF NRA identified actions in the following broad categories:

• Improve and develop understanding of risks.
• Test and strengthen existing controls.
• Build countering TF (CFT) capacity.
• Strengthen connections with internal and external stakeholders.

The 2023 report summarises the actions Jersey has taken in respect of these categories and reassesses Jersey’s exposure to TF risk.  This is based on additional information obtained to address the data gaps and recommended actions identified in the 2021 TF NRA. It also identifies opportunities to further strengthen controls and understanding, in an endeavour to counter potential TF risks satisfactorily.

The 2023 TF NRA forms part of Jersey’s continuous risk assessment work, including:

•  National Risk Assessment of Money Laundering  - September 2020
• National Risk Assessment of Non-Profit Organisations - April 2022
• National Risk Overview of Virtual Asset Service Providers - May 2022.

More information is available on GOV.JE website.

Licenced firms should familiarise themselves with all national risk assessments, legal and regulatory requirements and consider the following best practise:

• Review your business risk assessment and risk appetite to take account of any relevant updates within the national risk assessments;
• Continue to monitor against sanctions notices, reporting any suspicions where relevant.  When monitoring sanctions, ensure associated persons and family members are also considered;
• Ensure ongoing compliance monitoring is conducted, with results being reported to the Board;
• On-boarding, client due diligence and payment procedures should take into account terrorist financing risks;
• Remain vigilant and inquisitive;
• Train staff to recognise the risks associated with terrorist financing, consider typologies and red flags;
• Utilise good practise and guidance provided by the regulator and other relevant sources.