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ARTICLE · 14 JULY 2023

The New JFSC Outsourcing Policy: Overview, Impact And Actions Required

Ogier
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The JFSC has published the final version of its revised Outsourcing Policy, which will come into force on 1 January 2024 following a six month transitional period.

JerseyFinance and Banking
Matt McManus
Matt McManus
Niamh Lalor
Niamh Lalor
Sophie Reguengo
Sophie Reguengo
Emily Haithwaite
Emily Haithwaite
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The JFSC has published the final version of its revised Outsourcing Policy, which will come into force on 1 January 2024 following a six month transitional period.

The scope of the policy has been expanded to include businesses who are regulated under a wider range of regulatory laws. Notably:

  • the direct appointment of an AMLSP to fulfil AML/CFT/CPF obligations is not in scope (eg by "previously exempt supervised persons" who are now obliged to register for AML/CFT/CPF supervisory purposes under the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008)
  • however, where any part of a supervised person's AML/CFT/CPF function is outsourced other than under the AMLSP regime, this is in scope of this new policy

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