Submission #17

Primary tabs

View(active tab)

Government of Jersey

a) Do you consider that these guidelines are conducive to firms adopting risk-based, proportionate and effective AML/CFT policies and procedures in line with the requirements set out in Directive (EU) 2015/849?

The response of the Government of Jersey, is contained, in full, in the uploaded document.

b) Do you consider that these guidelines are conducive to competent authorities effectively monitoring firms’ compliance with applicable AML/CFT requirements in relation to individual risk assessments and the application of both simplified and enhanced customer due diligence measures?

The response of the Government of Jersey, is contained, in full, in the uploaded document.

c) The guidelines in Title III of this consultation paper are organised by types of business. Respondents to this consultation paper are invited to express their views on whether such an approach gives sufficient clarity on the scope of application of the AMLD to the various entities subject to its requirements or whether it would be preferable to follow a legally-driven classification of the various sectors; for example, for the asset management sector, this would mean referring to entities covered by Directive 2009/65/EC and Directive 2011/61/EU and for the individual portfolio management or investment advice activities, or entities providing other investment services or activities, to entities covered by Directive 2014/65/EU.

The response of the Government of Jersey, is contained, in full, in the uploaded document.

Upload files 21.01.2016 - GoJ Response to the ESA Consultation on 4MLD guidance .pdf

Name of organisation Government of Jersey