This document summarizes Jersey's model for collecting beneficial ownership information centrally for companies and partnerships. It discusses Jersey's long-standing policy of collecting this information, the 2012 FATF standards, and the 4th EU Anti-Money Laundering Directive. It also outlines Jersey's current process for collecting and verifying beneficial ownership data, plans to improve the timeliness of information, and efforts to leverage digital technologies to enable more seamless interaction. The document emphasizes Jersey's commitment to international standards for transparency and combating financial crime.

1. Beneficial Ownership – the Jersey model

2. › Agenda
› Jersey policy
› 2012 FATF standards
› 4th Anti-Money Laundering
directive of the EU
› E-enabling
› Current Jersey Process
› Future Jersey Processing
› Julian Lamb
Director, Registry
Jersey Financial Services
Commission

3. Located near
France, in the
Bay of St Malo
45 square
miles in size
Population of
app. 100,000
42,000
households
7,000
businesses
About Jersey

4. Jersey and the UK
Unique constitutional
relationship since
1204
UK has constitutional
responsibility for the
defense of Jersey
Jersey is autonomous and
self-governing - not part of
UK or EU
Centuries of diverse
and multi-cultural
society

5. ›
Jersey Policy

6. Current International Issues
International
Standards
Transparency Digital

7. ›Jersey has collected beneficial ownership information
centrally on Jersey companies and partnerships for over 20
years
›A policy designed to ensure the Companies Registry collects
adequate, accurate and current information on Jersey
companies and partnerships
›Different requirements imposed if company is incorporated
by a local resident or administered by a Trust and Company
Service Provider (“TCSP”)
› A central register of Beneficial Ownership

8. › Jersey has been recognised as an international
leader on transparency of beneficial ownership
›The World Bank report “The
Puppet Masters” outlined
the Jersey model as an
example
›Rated Largely Compliant by
the IMF against 2003 FATF
Recommendations in 2009
›Recently assessed by
MONEYVAL – positive
assessment
›Jersey continues to look to
improve the regime in
furtherance of the worldwide
fight against financial crime
›Consultation published last
week to ensure information
held centrally is as “current” as
reasonably possible

9. › The evolving “model”
Consultation recently published and closed on 7 April 2016:
www.gov.je/Government/Consultations/Pages/BeneficialOw
nershipofJerseyCompaniesandaRegisterofDirectors.aspx

10. › 2012 FATF standards

11. ›Standard is developing, both in the FATF and the EU
›FATF – R24 & Interpretive note to R24 & Interpretive note to
R10
›“Adaquate, accurate and timely information”
›“Adaquate” – 10% threshold on incorporation but ability to
ask for more
›“Accurate” – Registry team staffed by experts conducting
verification exercises
› Development of the International Standard

12. ›“Timely” information:
›Subject of our current consultation
›70% of companies administered by TCSPs – up to date
information must be held by the TCSP on beneficial
ownership and they are regulated by the JFSC
›Looking to develop intelligent digital interfaces to allow
secure information transfer to the central registry
›Ultimately to be able to provide as up to date information as
possible to law enforcement and tax authorities
› Development of the International Standard

13. › 4th Anti-Money
Laundering Directive
of the EU

14. › A major change across Europe
› Jersey is a “third country” to
the EU
› We observe activity in Europe
closely and have a Channel
Islands Brussels Office
(“CIBO”)
› 4MLD has been closely
observed
›The Jersey model will look to
match requirements of 4MLD
›4MLD, along with the FATF
guidelines will set the global
precedent on requirements for
information

15. › However…more advancement in Washington…
› The ‘Panama Papers’ and the
UK Anti-corruption summit
have intensified the
international initiative
› Spring IMF Finance Ministers
meeting resulted in a letter
from the ‘G5’ to the ‘G20’ on
automatic exchange of
information

16. › And then even more advancement in
Brussels…
› ECOFIN published a statement
following a meeting on 22 April
› All EU Members States + others
committed to the ‘pilot initiative’
› Not clear how it is to be
implemented but it is hoped that
a global standard will be
implemented through the FATF
› UK Anti-corruption summit on 12
May 2016 should make the route
forward clearer

17. › Consultation also has focus on Fintech solutions
› Jersey is on a Digital journey
› Jersey is looking to leverage its experience in regulation and
registration in the digital world
› The aim is to allow seamless interaction in a digital world for ease
of doing business in an international finance centre.
› E-enabling our regulated sector – the Digital
journey for Jersey

18. › Beneficial ownership information is inherent to information on
individuals
› Individuals regularly need to confirm their identity for numerous
reasons
› How can information on individuals, stored digitally, be used
more intelligently?
› Can the compliance headache be remedied by a central storage
solution?
› Expanding the possibilities….

19. › Current Jersey
Process

20. › Transparency for Registry (T4R) Programme
Overview
Outcomes
Customer/Industry
Increased
transparency
Excellent
customer
service
Simplification
of doing
business
Reduced
processing
times
Improved
data integrity
Sound Business
Practice Policy
Registry
dashboard and
SLA monitoring
Automated
processes
Programme of work
Registry processing
statement and
enhancement forms
Policies, procedures,
AML/CFT checks
Registry principles

21. ›Established a Sound Business Practice Policy successfully
adopted by our customers
›Publish the Registry Processing Statement (Service level
Agreement)
›Focus on improving transparency but retaining excellent
customer service levels (Balance the registry regulatory
burden with the ease of doing business)
›Important to the Jersey finance industry as supports
transparency and mitigates reputational risks to the Island.
› Transparency for Registry (T4R) Programme
Overview

22. › Future Jersey
Processing

23. ›Improved interoperability
›Leveraging the regulated sector
›Joining systems to help law enforcement and tax authorities
have access to information
›Cyber security
›BRIS and Europe
›The rest of the world
› E-enable

25. › We are in a time of un-paralleled change with political initiatives in this area
› Jersey is a leader in transparency of beneficial ownership information and is
fully committed to the worldwide fight against financial crime
› Observing developments internationally and keen to assist others from our
experience through technical assistance
› Robust process to ensure our information is adequate and accurate
› Our top priority is to combat financial crime and what is most important in this
respect is that law enforcement and tax authorities have access to information
that is adequate, accurate and up-to-date.
› We are a cooperative jurisdiction committed to complying with international
standards.
› How can we e-enable to ensure greater efficiency for business?
› Final thoughts

26. Thank you for your time
Julian Lamb
J.Lamb@jerseyfsc.org