Insights from the people doing the work

Altair had been looking for a community based program to support and we are delighted to sponsor Chirpy’s Cricket Academy.

Based in Jersey, Mike started his career as a discretionary manager, with responsibility for the offshore fund selection of Barclays Wealth, before moving into the fiduciary sector to lead the investment oversight and monitoring for Barclays Global Trust division.

In recently announcing its examination programme for 2020, the JFSC has emphasised the importance with which it regards the compliance monitoring programme (CMP).

The latest Consultation Paper (No. 10, 2018) from the Jersey Financial Services Commission (“the JFSC”) has floated the proposal that regulated entities which control client monies (other than banks) should implement an annual review of their relevant controls.

I couldn’t help but notice one of the more significant amendments proposed by the JFSC in Consultation Paper No. 10 (Amendments to the Codes of Practice) is the introduction of a requirement for registered persons to perform a regular review of their controls for client money.

The Proceeds of Crime and Terrorism (Tipping Off – Exceptions) Regulations 2014 (“the Regulations”) have been in place for a while now but after so many years of not daring to tell anyone anything at all about suspicious activity reports (“SARs”), some people are still very wary of taking advantage of the disclosures which are protected under the Regulations.

I should start with a caveat – I’m not a lawyer and I wouldn’t dream of claiming to be able to give legal advice.

Revisions to the Codes of Practice in March 2018 included a new requirement that all aspects of a registered person’s corporate governance arrangements be subject to regular review.

With only 6 months to go until the EU General Data Protection Regulation (GDPR) takes effect, both Jersey and Guernsey are working hard on implementing local data protection laws which meet GDPR requirements. Guernsey has recently published their draft legislation and Jersey’s is expected shortly.

On 6 June 2017, we spoke to members of the Jersey Compliance Officers Association on the subject of “Conflicts of Interest”.

Hopefully these observations don’t apply to you or your business, however they have all appeared in public statements issued by the Jersey Financial Services Commission over the past couple of years or so.

The JFSC has announced that cyber security is to be one of the themes to be assessed next year as part of their onsite examination programme.