New Outsourcing Policy And Guidance Notes For Jersey

On 1 March, the Jersey Financial Services Commission ("JFSC") published its new Outsourcing Policy and Guidance Notes, which will apply to all new outsourcing agreements from 1 June 2017. Existing outsourcing agreements must adhere to this new Policy as from 1 June 2018, but may elect to comply with the new Policy as from 1 June 2017, by filing an Outsourcing Notification form.

The new Policy is wider in scope than its 2011 predecessor, so we would recommend that all arrangements be reviewed, where a regulated entity is delegating activities. Policy and Procedure Manuals will also need to be updated.

Whilst some delegated activities are clearly out of scope, activities that are within scope, will need to be subject to a risk assessment. It will also be necessary to wait to receive a 'no objection' from the JFSC, before the delegation can go live.