Jersey PLC has identified its own vulnerabilities by issuing various NRA’s, most recent is the update to Terrorist Financing. These risks have been identified by working parties made up of Regulators, Government agencies and industry and have been split into sector specific risks to assist identify the relevant factors.

As risk evolves, so must Jersey’s approach to mitigation tools and this is why there are new NRA’s being issued, such as the Legal Person & Legal Arrangements NRA. Interesting to note that Trusts remain the higher risk mainly due to the lack of data held.

At a recent seminar, the Government of Jersey issued some statistics around our regulatory risk and discussed how context is so important when reviewing them. For example, TCB have an average of 30% higher risks to Banking’s 4.9% high risks. It will be up to the Government and the JFSC to make sure this context is relayed clearly to MONEYVAL when they visit.

So, Jersey has identified its risks and has put in play many risk mitigation tools via laws, notices and regulation. However the passing of time from when the first NRA’s were issued allows Jersey, in some instances, the ability to benchmark and check that these remain robust. And, they and have used the skills of external parties like Royal United Services Institute to test that they remain fit for purpose.