A Jersey KYC file can contain a passport, an ownership chart and a clear screening result and still leave the approver unable to explain who controls the structure or what activity to expect. Completing customer due diligence means resolving those questions and keeping the evidence current.
This guide covers customer due diligence for funds, administrators, banks, brokerages, asset managers, and trust and company service providers in Jersey, Channel Islands. It draws on the JFSC AML/CFT/CPF Handbook, whose current index dates the consolidated version to 30 June 2026. Individual sections have their own effective dates. For help working the files, see our Jersey KYC services.
Start with the rules that apply to your entity
The Money Laundering (Jersey) Order 2008 and the JFSC Handbook use customer due diligence, or CDD, for the identification and ongoing monitoring measures often described operationally as KYC.
The Handbook separates statutory requirements, AML/CFT/CPF Codes of Practice and guidance notes. Statutory requirements and the applicable Codes are mandatory. Guidance describes ways to comply; do not turn every example in the guidance into a legal requirement. The workflow suggestions below are AgentKYZ’s operating recommendations.
Read the general sections together with the relevant sector-specific material. Sections 3 and 4 cover identification measures, Section 6 ongoing monitoring and Section 7 enhanced CDD. Section 13 covers fund and securities services activities; Section 12 addresses trust company service providers.
Our recommendation is to record the legal entity, its role, the applicable Handbook sections and its approved policy before defining a review checklist. A group policy or a shared document store does not establish which obligations each entity has met.
Adapt CDD to the service and customer relationship
Funds and administrators. Section 13 distinguishes the obligations of each supervised person. A fund and its administrator may need different risk assessments and checks even when they use the same investor documents. Where an administrator acts both for itself and as the fund’s delegate, distinguish the work performed in each capacity.
Banks. Apply the common CDD framework to the account holder and relevant connected parties, with an understanding of the purpose of the relationship and expected activity. For a remediation project, our recommendation is to test whether the recorded profile explains the account’s use and to flag unexplained differences for review. Document refreshes alone do not cover transaction monitoring or payment-related obligations.
Brokerages and asset managers. Define the relationship being reviewed: for example, an individual investment client, a corporate mandate or a fund relationship. Use the relevant fund and securities provisions in Section 13 alongside the general requirements. Our scoping recommendation is to distinguish the client from intermediaries and other parties in the arrangement, then agree whose identity, authority and control need evidence.
Trust and company service providers. Read Section 12 alongside the general identification requirements. The CDD scope depends on the service and legal arrangement. We recommend recording the parties’ roles, how control operates and the purpose of the structure before requesting evidence. A trust relationship needs its own assessment; a company-shareholding checklist will not explain every relevant role.
These are starting points for scoping file work, not complete sector compliance checklists. Confirm the measures required for the specific entity, activity and risk before applying them to a customer population.
Identify ownership and control beyond the chart
The general identification requirements in Sections 3 and 4 address ownership and control. For fund and securities services, Section 13, paragraph 48, describes the Three Tier Test: control through ownership, control through other means and, where neither identifies an individual, control through positions held. An ownership-percentage filter alone cannot answer all three questions.
For a corporate customer or investor, trace the chain to the relevant individuals and record how control operates. Voting rights, appointment powers or other arrangements may explain control that a shareholding chart misses. Where a trust is involved, identify the relevant parties and their roles under the applicable requirements.
Complexity is a risk factor to understand. Section 13 calls for a case-by-case assessment; one higher-risk indicator does not automatically make the whole relationship high risk. Layers that obscure control or lack an intelligible purpose need further investigation.
In a working file, connect each ownership or control conclusion to its source document. If the evidence stops at an intermediary, record the missing evidence and who will obtain it. A diagram with an unresolved ownership link should remain an open issue at handover.
Match enhanced due diligence to the risk and requirement
Use Section 7 of the Handbook when deciding which enhanced CDD measures apply. Assess the customer and relevant connected parties, their jurisdictions, activity and structure. PEP connections, adverse information or an opaque arrangement may require additional work, escalation and approval under the applicable rules and your policy.
Keep source of funds and source of wealth distinct. Source of funds explains the origin of money used in a transaction or relationship; source of wealth explains how the person accumulated their wealth. Decide what information and corroborating evidence are needed for the particular relationship. A bank transfer identifies the account the payment came from but may not explain the underlying origin of the money.
Our file-work recommendation is to record the risk identified, the additional checks performed, the supporting evidence and any unresolved concerns. Screening results need a recorded disposition: a possible name match is neither a confirmed match nor a reason to clear the file without review.
Set periodic review dates and respond to trigger events
Section 6, paragraphs 18–23, describes risk-sensitive periodic reviews and trigger-event reviews. Review frequency should reflect the customer risk rating and be documented in the firm’s policies. Avoid treating an annual refresh as a universal JFSC rule.
Triggers include changes in ownership or control, unusual activity, new adverse media or PEP information, and material changes in a structure or its beneficiaries. A relevant event can require a review before the next scheduled date.
Section 13 adds fund-specific examples, including significant additional subscriptions or drawdowns, distributions and mergers admitting new investors. Review the circumstances rather than assuming every movement has the same effect on the file.
A periodic document refresh covers only part of ongoing monitoring. The firm also needs to scrutinise activity against its understanding of the customer and expected transactions. For outsourced file reviews, specify which monitoring tasks are included and which remain with the firm or another service provider.
Separate outsourcing, reliance and AMLSP appointments
These arrangements have different legal conditions. A contract calling work “KYC outsourcing” does not establish a statutory reliance arrangement or appoint an AML service provider.
Ordinary outsourcing. Another party performs agreed work on the firm’s behalf. For fund and securities services, Section 13.8.4 explains that the delegating supervised person remains responsible, needs oversight and must receive enough information to monitor the work. Check the outsourcing provisions applicable to your entity and activity, including the JFSC Outsourcing Policy where relevant and any notification or no-objection requirements, before starting.
Reliance on an obliged person. This is a specific route under the Money Laundering Order and Section 5 of the Handbook. Check who qualifies, which identification measures can be relied on, and the information, assurance and access conditions. Receiving a completed file from another business does not by itself satisfy those conditions.
An Article 9A AMLSP appointment. Section 15 covers eligible supervised persons appointing an anti-money laundering services provider. That formal arrangement includes responsibilities beyond reviewing files, including the appointment of AML officers. AgentKYZ’s managed KYC engagement is operational support and does not replace such an appointment.
As at 5 October 2026, the JFSC’s Handbook update notice identifies further reliance and MLCO changes for 31 October 2026. The notice says the risk-based approach to MLCO appointment cannot be used until the Handbook is updated. Check the effective provisions before changing either arrangement; do not apply an announced future permission early.
Keep evidence of oversight and remediation
Section 2 covers governance and the effectiveness of systems and controls. For fund and securities services, Section 13 also explains oversight of delegated CDD. A completion percentage can show progress, but the firm also needs to understand the work performed, the exceptions and the decisions still required.
For a remediation project, we recommend agreeing these records at the start:
- A defined file population and the policy version used for testing.
- Findings tied to source documents and the relevant check.
- A distinction between resolved gaps, missing evidence and escalations.
- An owner and target date for each outstanding action.
- Reviewer notes and evidence of the authorised team’s decisions.
Agree how the firm can retrieve underlying records, including after an engagement ends, and check retention requirements against Section 11 and the Money Laundering Order. Put access, confidentiality and data-handling terms in place before sharing customer documents.
File testing can inform the board’s oversight and identify remediation work. Its scope is narrower than a programme-wide AML audit, which may also need to assess governance, reporting, training and the operation of wider controls.
Turn the findings into a scoped KYC project
Start with the population, available documents, risk methodology and target date. Agree which checks belong to your firm, which another party performs and who handles missing evidence or escalations. Prioritise the backlog under the firm’s risk assessment.
Our managed KYC services for Jersey financial services firms cover onboarding, CDD remediation and periodic reviews under your approved policy. We support funds and administrators, banks, brokerages, asset managers, and trust and company service providers. Agents organise the evidence and perform the first pass; qualified compliance reviewers check the work. Your authorised team keeps the decisions. Send the case count and target date to agree the scope, price and delivery schedule.