Policy Brief
Financial Services
The financial services industry accounts for nearly 40% of economic activity in Jersey, and around 70% of tax revenue.
Regulatory regime
The Jersey Financial Services Commission (JFSC) is the Island’s financial regulator. Its mission is to maintain Jersey's position as a leading international finance centre, with high regulatory standards.
It supervises businesses in respect of their compliance with the obligation to counter money laundering, terrorist financing and proliferation.
The JFSC operates around guiding principles which are -
- reducing risk to the public of financial loss due to dishonesty, incompetence, malpractice or the financial unsoundness of financial service providers
- protecting and enhancing the reputation and integrity of Jersey in commercial and financial matters
- safeguarding the best economic interests of Jersey
- countering financial crime both in Jersey and elsewhere
Its statutory responsibilities are set out in the Financial Services Commission (Jersey) Law 1998 and include –
- authorising, supervising, overseeing and developing financial services in Jersey
- enforcing the Commission Law
- reporting, advising, assisting and informing the Government of Jersey and public bodies
- developing policies
- operating the Companies Registry.
Money laundering and financing terrorism
In September 2022 Jersey’s National Strategy for Combatting Money Laundering, the Financing of Terrorism and the Financing of Proliferation of Weapons of Mass Destruction was published. This lists seven strategic priorities -
1. Understanding the threat and performance metrics.
2. Better information sharing and co-ordination.
3. Powers, procedures, preventative measures, and tools.
4. Enhanced capabilities of law enforcement, the justice system and private sector.
5. Risk-based supervision and risk management.
6. Transparency and ownership.
7. International strategy .
The priorities are supported by an action plan.
The Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism - MONEYVAL - is a permanent monitoring body of the Council of Europe directly to the Committee of Ministers.
The aim of Moneyval is to ensure that its members have effective systems in place to counter money laundering and terrorist financing and comply with the relevant international standards in these fields -
- Recommendations of the Financial Action Task Force (FATF), including the Special Recommendations on Terrorist Financing.
- 1988 United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances.
- United Nations Convention against Transnational Organised Crime.
- 1999 United Nations International Convention for the Suppression of the Financing of Terrorism.
- Directive 2005/60/EC of the European Parliament and of the Council of 26 October 2005 on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing and the relevant implementing measures.
- 1990 Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime, concluded within the Council of Europe.
Moneyval undertakes a number of tasks in relation to this, including being entrusted with the task of assessing compliance with all relevant international standards to counter money laundering and the financing of terrorism and the effectiveness of their implementation, as well as with the task of making recommendations to national authorities in respect of necessary improvements to their systems.
Through a dynamic process of mutual evaluations, peer review and regular follow-up of its reports, Moneyval aims to improve the capacities of national authorities to fight money laundering and the financing of terrorism more effectively.
In November 2022 Moneyval launched its fifth-round mutual evaluation process of Jersey. The report was published on 24 July 2024. The text of the press release is set out below.
In a report published today, the Council of Europe’s anti-money laundering body MONEYVAL commends the UK Crown Dependency of Jersey for taking steps to strengthen its legal and regulatory framework to combat money laundering (ML), financing of terrorism (FT) and financing of proliferation (FP). It also calls on the jurisdiction to further reinforce the practical application of its frameworks for investigations and prosecutions for ML, as well as the enforcement of sanctions related to AML/CFT preventative measures.
The Council of Europe’s anti-money laundering body conducted a comprehensive assessment of the country’s level of compliance with international standards set by the Financial Action Task Force (FATF).
MONEYVAL concludes that, having significantly strengthened its legal framework since the last mutual evaluation, Jersey has most elements of an effective AML/CFT, but still needs to improve the implementation of measures in certain areas.
On the operational side, Jersey has achieved a high level of effectiveness for its understanding of ML/TF risks and implementing adequate AML/CFT policies and strategies to mitigate them. The report commends the authorities for concluding multiple high-quality, comprehensive and detailed risk assessment products informed by a variety of sources. National co-ordination and co-operation between agencies, as well as private sector awareness of risks are also strengths of the system.
The operational independence of Jersey’s Financial Intelligence Unit (FIU) and its resources have significantly improved since the last MONEYVAL assessment. Financial intelligence is regularly used to develop evidence and trace proceeds in ML, TF and predicate offence investigations, although the trend is relatively recent and authorities are encouraged to make increased use of these resources. While ML cases are routinely investigated and proceeds of crime are pursued as a policy objective, the modest number of ML prosecutions, including those for third-party and autonomous ML, call for a more proactive approach by the competent authorities. However, MONEYVAL recognises the positive results of alternative measures put in place such as civil forfeiture mechanisms, introduction of deferred prosecution agreements and the introduction of a criminal offence of the failure to prevent ML.
Jersey has appropriate mechanisms in place to identify, investigate and prosecute TF. The low number of investigations and the absence of prosecutions and convictions has been assessed as consistent with the jurisdiction’s low TF risk profile. Mechanisms to implement, without delay, targeted financial sanctions (TFS) on terrorism financing and proliferation financing are equally in place. Notwithstanding, the assessment detects room for improvement regarding supervision of TFS requirements and the risk-based oversight of the non-profit sector.
Steps have been undertaken to reinforce the AML/CFT supervisory framework, which concentrates on the higher-risk entities and sectors, in line with supervisors’ good understanding of risks. However, the approach to ensure compliance with AML/CFT obligations greatly relies on remedial actions, with a modest imposition of sanctions, which is not considered to be sufficiently in line with the number and types of breaches detected. Measures aimed at preventing criminals from entering the market are in place for all sectors, but the report calls for a more robust process for conducting criminality checks.
The private sector demonstrated a good level of understanding of the risks and compliance with AML/CFT obligations. However, the report makes clear that the private sector’s implementation of measures on complex structures, assessment of the risks for the application of exemptions, application of enhanced due diligence measures (EDD) to politically exposed persons (PEPs) and the detection and prompt reporting of suspicious transactions would merit further improvements.
MONEYVAL finds that Jersey authorities demonstrated a good understanding of the extent to which legal persons and arrangements can be misused for ML purposes. Jersey ensures the availability of adequate, accurate and up-to-date basic and beneficial ownership (BO) information of legal persons and arrangements through a fully populated Registry and trust and company service providers (TCSPs), as well as conducting comprehensive checks, risk assessments and vetting processes on an ongoing basis.
Jersey authorities demonstrated commendable efficiency in actively seeking and providing mutual legal assistance (MLA) and other forms of international co-operation, particularly in the later years of the assessed period. Similar conclusions were drawn regarding the process of BO information sharing. Nevertheless, authorities are encouraged to seek informal cooperation more frequently and continue to increase their outreach to foreign counterparts via MLAs.
Jersey is expected to report back to MONEYVAL under its regular follow-up reporting process in December 2026.
OECD initiative on taxation
The international tax policy landscape is evolving rapidly, with new cross-border initiatives being developed and rolled out at pace. Key to this agenda is the Organisation for Economic Cooperation and Development (OECD) two pillar tax initiative that is aimed at large multinational groups.
Jersey is a founding member of the OECD Inclusive Framework on Base Erosion and Profit Shifting (BEPS) and joined the international consensus of 137 Inclusive Framework member jurisdictions on the two pillar initiative in October 2021. Jersey is thus committed to implementation of the Minimum Standards contained in the two pillar package.
The Pillar One Minimum Standard targets the largest and most profitable global multinational groups – those with annual revenues of at least €20 billion and a profitability margin above 10%. It seeks to allocate a share of residual profits earned by qualifying groups across jurisdictions, based on the location of the group’s customers. Of particular relevance for Jersey, it will contain an important exclusion for certain regulated financial services businesses.
Pillar Two comprises a Minimum Standard treaty-based measure called the Subject to Tax Rule, which is intended to ensure that developing countries are not disadvantaged by low withholding tax rates in their Double Tax Agreements (DTAs). As a Minimum Standard, Jersey – along with other jurisdictions – will be required to implement this rule, to the extent that any of Jersey’s DTAs are not in line with the rules when they are ultimately finalised later in 2022 or into 2023.
The second part of the Pillar Two package is a significant new Global Anti-Base Erosion (GloBE) regime. GloBE is a set of international tax rules that have been carefully designed with interlocking mechanisms to ensure that in-scope multinational groups will pay a 15% minimum effective rate of taxation in each jurisdiction in which they operate.
In April 2022, the Government of Jersey published a consultation paper entitled OECD Pillars 1 & 2: tax policy reflections. The aim of the paper was to provide as much clarity as possible on Jersey’s position regarding the two pillars, to assist in-scope groups in their preparation for global implementation.
The next 12 months will be key to the global implementation of this OECD initiative. Jersey officials continue to participate in intensive OECD technical discussions on design aspects of Pillar One and on the Pillar Two GloBE implementation framework. This includes important work on GloBE “safe harbours”.
Jersey is also carefully monitoring the international developments on GloBE adoption in the EU, US, UK and elsewhere. No political decision has yet been taken on GloBE implementation in Jersey – that will be a matter for the States Assembly to determine, when the landscape on global implementation becomes clearer.
Financial Services Policy Framework
The Financial Services Policy Framework was published in December 2021. This includes a comprehensive analysis of the current position of the financial services industry in Jersey. It lists ten strategic priorities -
1. Maintain and develop the four pillars [private wealth, funds, capital markets and banking] of Jersey’s financial services industry.
2. Enable Jersey to be a leading international financial centre for sustainable finance.
3. Harness the opportunities created by fintech and digitalisation.
4. Maintain an attractive and agile operating environment.
5. Maintain strong adherence to international standards.
6. Review and refresh Jersey’s strategy for combatting financial crime.
7. Enhance Jersey’s profile internationally.
8. Grow and deepen Jersey’s footprint in new and existing markets.
9. Deliver strong and effective stakeholder cooperation.
10. Deepen and broaden the skills and expertise of Jersey’s workforce.
Business Plan 2025
The Department for the Economy Business Plan for 2025 has the following section on financial services and financial crime strategy.
“Publish an updated action plan that addresses findings of the MONEYVAL Fifth Round Mutual Evaluation Report on Jersey.
We will publish the report, including potential legislative or policy changes to Jersey’s financial crime prevention framework and commence cross-agency work, to deliver on those actions and to prepare for the next-round assessment.
The outcome of the MONEYVAL assessment puts us in a strong position to consider competitiveness and sustainable growth for the financial services sector. We will continue the work of the Ministerial Working Group on International Competitiveness during 2025. We will:
- Undertake a strategic review of the legislative and regulatory environment that supports
- Jersey’s financial and professional services sector to promote competitiveness and continued compliance with global standards
- Lodge amendments to the Companies (Jersey) Law 1991
- Lodge amendments to the Trusts (Jersey) Law 1984 that will ensure the continued flexibility of the Law and enhance the ease of doing business in the context of evolving industry practice and within an appropriate and legitimate framework
- Consult on and lodge amendments to the Security Interests (Jersey) Law 2012 that will address issues of legal and uncertainty and technical difficulties which have emerged since the law’s inception
- Continue to deliver actions arising from the Sustainable Finance Action Plan published in November 2024
We will continue our work on a consumer credit regime to ensure an adequate and proportionate regime for Jersey, by finalising and lodging secondary legislation.”
Financial Services Competitiveness Programme
On 22 April 2025 the Government announced a Financial Services Competitiveness Programme. The press release is reproduced below.
The Government of Jersey has launched its Financial Services Competitiveness Programme, a major strategic initiative aimed at strengthening Jersey's position as a globally attractive and forward-looking International Finance Centre (IFC).
This comprehensive programme is designed to support and enhance Jersey's financial and related professional services (FRPS) sector – the Island's largest employer and the most significant contributor to tax revenues that fund public services. It brings together several government departments, the Jersey Financial Services Commission (JFSC), Jersey Finance, Digital Jersey, and representatives from across the financial and professional services industry.
The Financial Services Competitiveness Programme will deliver clear, actionable recommendations focused on improving Jersey's regulatory and business environment, enhancing its global positioning, and preparing the sector for future opportunities and challenges.
The programme is governed by a Ministerial Working Group, chaired by the Minister for External Relations with responsibility for Financial Services, Depuy Ian Gorst, with the Chief Executive Officer, Dr Andrew McLaughlin, acting as the Senior Responsible Officer. They will be supported by a cross-government team of officials.
Deputy Ian Gorst said: “Jersey's financial services industry is a key growth engine of our economy. It is central to Jersey's prosperity and our ability to reinvest in and regenerate the Island. Through the Financial Services Competitiveness Programme, we are setting out a bold, coordinated plan to ensure Jersey remains an attractive, agile, and forward-looking International Finance Centre.
“This initiative shows that we are not content to stand still – we are proactively investing in the Island's future, and working in partnership across government, industry, and the regulator to deliver sustainable, long-term success.
“Jersey has a proud 60-year history as a trusted, stable, and innovative IFC. However, global economic shifts, regulatory changes, tax policy evolution, Brexit, post-pandemic recovery, and rapid technological advancement mean that IFCs around the world – including Jersey – must continuously adapt to stay competitive. The Financial Services Competitiveness Programme is Jersey's response: a future-focused, evidence-led strategy to sustain and expand the Island's most vital economic sector."
Programme structure and key workstreams
The programme is built around four core workstreams, which will be managed in a phased approach.
- International Tax Strategy – Led by Revenue Jersey, this will focus on maintaining Jersey's strong position through a forward-looking tax policy.
- Business & Regulatory Environment – Led jointly by the Government and the JFSC, this aims to improve the ease of doing business, delivering quick-win reforms as well as medium- and long-term changes to enhance the Island's appeal to global investors.
- External Growth Strategy – A global market analysis to inform Jersey's external engagement strategy, identifying future value pools and Jersey's competitive positioning, led by the Government with expert support from Jersey Finance Ltd.
- Future Competitiveness & Regulation – Bringing together insights from all workstreams, this phase will culminate in a report by an independent panel of global experts.
The first phase, which is underway already, will focus on improvements to Jersey's business and regulatory environment. This will involve making positive changes to improve the ease of doing business and to help maintain and grow the Island's FRPS sector as it competes in the market today. As recent global economic volatility has demonstrated, it is more important than ever that Jersey invests in optimising its business and regulatory environment to increase its competitive edge.
The Government will publish a report on progress in delivering the programme together with an action plan on next steps in spring 2026.
Industry engagement
The Government will engage regularly with stakeholders through:
- Industry events and “roundtable" discussions
- Updates at Financial Services Advisory Board meetings
- Briefings for States Members and Scrutiny Panels
- Ongoing consultation and feedback channels
More information is available on the Government of Jersey website: Financial services competitiveness programme.
Jersey Finance
Jersey Finance is the representative and promotional body for the finance industry in Jersey. It is funded by the Government and the industry. Its website includes detailed papers on the industry.