Introduction
The scope of Jersey's anti-money laundering,
counter-terrorist financing, and counter proliferation financing
regime (the "AML Regime") has been
amended to closer align with the Financial Action Task Force's
International Standards on Combating Money Laundering and the
Financing of Terrorism and Proliferation (the "FATF
Recommendations"). As a result, entities that
weren't previously in scope under the Proceeds of Crime
(Jersey) Law 1999 (the "Proceeds of Crime
Law") may now be in scope.
The revisions introduce new terminology, much of which is
broadly drawn. Some terminology features in other laws or
regulations, or has been interpreted by the courts in Jersey or
elsewhere, and the interpretation is supplemented by both guidance
issued by the Jersey Financial Services Commission (the
"JFSC") and the FATF Recommendations and
methodology. Discerning the exact perimeter of the AML Regime is no
simple task, however. To some, it may be reminiscent of
