--- title: "JE Payments Regulation Monitor | World Payments Monitor" canonical: https://payments.gi/jurisdictions/jersey/ source_html: /jurisdictions/jersey/index.html description: "JE payments and e-money regulation: 14 modules, 55 sourced findings, updated 2026-10-26. Licensing, safeguarding, stablecoins, AML/CFT." generated_at: 2026-10-26T23:52:31Z content_sha256: 2f643078e1af1db27f3aa5deddfa90658b028379864d7d8f4b5770e178e1c15a generator: "fe-fleet/md-twin@1.0" --- # JE JE schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-26 · 14 modules · 55 sourced findings · 143 sources in the cumulative register Download report (PDF) Expand all 14 Modules 0 Moved this cycle 1 Key judgments 4 Open gaps 55 Findings 35 Tier-1 sources Confidence mix 13 unpopulated 1 confirmed (sums to 14 rendered modules; click to filter) No modules moved this cycle. ## Jurisdiction brief Jurisdiction lead brief 638 Full executive summary 505 ###### Latest update · 25 October 2026 #### Lead Signal Jersey's payments-relevant financial crime architecture has been materially tightened by a confirmed change to the reliance and Money Laundering Compliance Officer regime that reaches payment companies and crypto-asset operators directly, not only trust and fund administrators. The Jersey Financial Services Commission has finalised the remaining provisions of the amended Money Laundering (Jersey) Order 2008, removing a fixed numerical threshold for when a firm must appoint an MLCO in favour of a risk-based assessment conducted by the firm itself, tightening third-party reliance arrangements, and taking effect 31 October 2026. For non-bank payment institutions and e-money issuers licensed in Jersey, this changes a mechanical compliance trigger into a documented risk-judgment exercise, with the obligation applying across the regulated population regardless of whether the firm is bank-affiliated or operates as a standalone payment or e-money licensee. This development is carried into the payments view because it originates in the jurisdiction's AML/CFT regime generally rather than in payments-specific rulemaking, and it is surfaced here as the financial-crime-control backdrop against which payment and e-money firms operating from or through Jersey must now calibrate their own governance arrangements, rather than as a new illicit-finance analysis in its own right. #### Other Developments No other in-window material change was identified across Jersey's remaining payments modules. #### Cross-Monitor Connections The reliance and MLCO regime change is sourced from the jurisdiction's financial-crime compliance architecture rather than from payments-specific regulatory activity, and its relevance to payment and e-money institutions lies specifically in how it alters the governance obligations those institutions carry as regulated businesses under Jersey law. The change does not itself constitute a payments-market, licensing or scheme development; it is a financial-crime control question that happens to apply to payment companies among other regulated sectors. #### Outlook The operative date of 31 October 2026 is the point at which payment and e-money institutions licensed in Jersey will need to have completed the risk-based assessment that now substitutes for the prior fixed MLCO threshold, and tightened reliance arrangements will take practical effect for any payment or e-money firm that previously depended on due diligence conducted by another regulated entity in a group or distribution-partner structure. 1 earlier update not shown here. ###### Standing brief · as of 5 October 2026 Written before the update above. Where they differ, the update is the more recent position. #### Lead Signal Jersey's statutory foundation for market access moved procedurally this cycle. The Companies (General Provisions) (Jersey) Amendment Order 2026 came into force on 30 September 2026, updating the statutory basis underpinning prospectus requirements and the Jersey Private Fund approval regime. No substantive change to the Jersey Private Fund regime itself was identified; the amendment updates the statutory scaffolding around which that regime operates rather than its substantive approval criteria. This sits within the Government of Jersey's wider Financial Services Competitiveness Programme, a standing policy initiative under which Jersey's statutory financial-services framework is being periodically reviewed and updated. The amendment is best read as an instance of that programme at work rather than as an isolated legislative event. #### Other Developments Statutory base for prospectus and fund approval updated. The amendment Order's effect on prospectus requirements runs alongside its effect on the Jersey Private Fund approval regime, meaning both the public capital-raising route and the private fund route for market access in Jersey now operate under the updated statutory foundation from 30 September 2026 onward. #### Cross-Monitor Connections No cross-monitor connections are supported by this cycle's substrate for Jersey's licensing and market-access posture. #### Outlook With no substantive change identified to the Jersey Private Fund approval regime itself, the practical question for market participants is whether the Financial Services Competitiveness Programme produces a further, more substantive update to the JPF regime in a subsequent cycle, or whether this amendment represents the extent of near-term change to Jersey's fund and prospectus market-access framework. Read full brief · 638 words ###### Latest update · 25 October 2026 #### Regulatory Status Jersey's payments-relevant regulatory position this period is defined by a confirmed change to the financial crime compliance architecture that reaches payment and e-money institutions directly. The Jersey Financial Services Commission has finalised the remaining provisions of the Money Laundering (Jersey) Amendment Order 2026, removing the fixed numerical threshold for Money Laundering Compliance Officer appointment in favour of a risk-based assessment the firm conducts itself, and tightening third-party reliance arrangements for customer due diligence. These remaining provisions take effect on 31 October 2026. The obligation applies across the regulated population of payment companies, electronic money institutions, crypto-asset operators, investment firms and other cross-sector obliged entities, without distinguishing bank-affiliated payment providers from standalone non-bank payment institutions in how the requirement attaches. No other in-window material change was identified across Jersey's payments-specific modules, including licensing and market access, conduct and safeguarding, stablecoin and digital-money frameworks, operational resilience, scheme compliance, corridor dynamics, industry structure, litigation, merchant acquiring, product innovation, consumer protection, correspondent banking and commercial intelligence. #### Outlook The commencement of the amended order on 31 October 2026 is the near-term marker for payment and e-money institutions licensed in Jersey, after which firms will need to demonstrate documented risk-based justifications for MLCO-appointment decisions and compliance with the tightened reliance standard for any due diligence previously conducted through reliance arrangements with other regulated entities. ###### Standing brief · as of 11 October 2026 Written before the update above. Where they differ, the update is the more recent position. #### Regulatory Status Jersey's payments-relevant regulatory landscape moved on two distinct axes this cycle. On market access, the Financial Services Competitiveness Programme delivered the Control of Borrowing (Jersey) Amendment Order 2026 (in force 13 April 2026) and the Companies (General Provisions) (Jersey) Amendment Order 2026 (in force 30 September 2026), both reducing consent-based friction for capital-raising and prospectus circulation, with full COBO repeal proposed from 1 October 2026. On licensing, Jersey continues to operate without a dedicated EMI/PI regime, routing e-money and money-transmission activity through the single Money Service Business Code of Practice under the Financial Services (Jersey) Law 1998 — illustrated this cycle by the Bloomsbury Money MSB (e-money) licence grant announced 12 May 2026. On consumer protection, the JFSC joined the Guernsey Financial Services Commission and the Isle of Man Financial Services Authority in publishing a joint Crown Dependencies APP Fraud Framework (7 July 2026), scoped initially to sterling retail Faster Payments and CHAPS transactions and deliberately diverging from the UK's mandatory fifty-fifty inter-bank cost-sharing regime by proposing no inter-bank cost-sharing mechanism at this stage. Commercially, Jersey-domiciled digital-asset firms CoinShares PLC (Nasdaq listing, 1 April 2026) and Komainu (Jersey) Limited (VARA Dubai operating licence) both expanded their international footprint while retaining their Jersey regulatory base. #### Outlook The proposed full repeal of Control of Borrowing requirements, announced 1 October 2026, and the scope and cost-sharing stance of the Crown Dependencies APP Fraud Framework are the two developments most likely to generate further movement. Both should be tracked as the near-term markers for Jersey's payments regulatory trajectory. Read full brief · 505 words × 14 of 14 modules Signal Moved Judgment Gap Density Comfortable Compact Expand all sources Reset all Selections OR within a group, AND across groups. Press / to search. ### W1aLicensing, Authorisation & Market Accesslimited signalProbableconfirmed 2026-09-08▾# Jersey's statutory foundation for market-access instruments (company-law prospectus requirements and the Jersey Private Fund approval regime) was updated via the Companies (General Provisions) (Jersey) Amendment Order 2026 and the Companies Law (Jersey) Amendment Order 2026, both in force 30 September 2026, as part of the Government's Financial Services Competitiveness Programme. No change to payment-institution or e-money-institution licensing routes was found. Standing sub-brief · as of 5 October 2026 288 words · last cycle 2026-10-11 #### Licensing, Authorisation & Market Access Jersey's market-access statutory base was updated this cycle via the Companies (General Provisions) (Jersey) Amendment Order 2026, which came into force on 30 September 2026. The Order revises the statutory foundation underpinning two distinct market-access routes in Jersey: prospectus requirements for public capital-raising, and the approval regime governing Jersey Private Funds. Research this cycle did not identify any substantive change to the Jersey Private Fund approval regime's own criteria or process; the amendment instead updates the statutory scaffolding within which that regime, and the prospectus regime, sit. The amendment forms part of the Government of Jersey's Financial Services Competitiveness Programme, under which the jurisdiction's statutory financial-services framework is subject to ongoing review. Reading this amendment in that context, it is a maintenance-level legislative update to the legal base supporting existing market-access routes rather than a change to licensing policy, authorisation thresholds, or the substantive test applied to new entrants seeking Jersey Private Fund approval or prospectus clearance. For firms and advisers tracking Jersey's licensing and market-access framework, the practical implication of this cycle's development is limited: the routes to market via prospectus and via Jersey Private Fund approval remain available on the same substantive terms, now resting on an updated statutory foundation from 30 September 2026. No change to fees, approval timelines, or eligibility criteria was identified in connection with this amendment. #### Outlook The open question arising from this cycle is whether the Financial Services Competitiveness Programme will, in a subsequent cycle, produce a more substantive revision to the Jersey Private Fund regime's approval criteria or scope, building on the statutory foundation now updated by this amendment Order, or whether this procedural update represents the extent of near-term legislative activity in this area. Read full sub-brief · 288 words Periodic update · new data 2026-10-11 #### Licensing, Authorisation & Market Access Jersey operates a single-gateway licensing model for payment-type activity rather than a dedicated electronic-money-institution or payment-institution regime distinct from its Money Service Business classification. The Money Service Business Code of Practice, issued under Article 19 of the Financial Services (Jersey) Law 1998, is the controlling instrument for electronic-money issuance, money transmission and bureau-de-change activity alike. This is a structural feature of the island's regulatory architecture, not a gap: Jersey has chosen to fold what many larger jurisdictions treat as distinct licence categories into one classification administered by the Jersey Financial Services Commission. The practical operation of this model was illustrated this cycle by the grant of a Money Service Business licence with e-money permissions to Bloomsbury Money, operating as DMALINK Jersey Limited, announced 12 May 2026. The licence empowers the issuance of electronic money alongside money transmission and bureau-de-change activity under the single MSB authorisation, confirming that new entrants seeking to issue e-money in Jersey route through the same gateway as traditional money-transmission businesses, with no separate prudential capital regime distinguishing the e-money activity from the rest of the MSB population. This single-gateway structure has implications for how the bank-versus-non-bank distinction is read in Jersey's market. Because there is no separate EMI authorisation tier, a non-bank payment institution entering the e-money space faces the same MSB Code of Practice obligations as an incumbent money-transmission business, rather than a lighter-touch or EMI-specific prudential framework of the kind found in jurisdictions with a dedicated e-money-institution category. This is a material difference for any non-bank entrant assessing Jersey as a market-access point: the regulatory burden is calibrated to MSB status generally, not to the specific risk profile of e-money issuance as distinct from money transmission. #### Outlook No announced plans to introduce a dedicated EMI/PI tier distinct from the MSB classification were identified this cycle. New entrants pursuing e-money or money-transmission activity in Jersey should expect to continue routing through the single MSB gateway under the Financial Services (Jersey) Law 1998 for the foreseeable future, with licensing decisions such as the Bloomsbury Money grant serving as the operative precedent for how the Commission applies that gateway to e-money-specific business models. Evidence 6 Sources and findings (6) - T2[https://www.bedellcristin.com/knowledge/briefings/financial-services-regulation-in-jersey/](https://www.bedellcristin.com/knowledge/briefings/financial-services-regulation-in-jersey/)retrieved 2026-09-08 - T1[https://www.jerseyfsc.org/industry/sectors/money-service-business/](https://www.jerseyfsc.org/industry/sectors/money-service-business/)retrieved 2026-09-08 - T3[https://www.prnewswire.com/news-releases/bloomsbury-money-secures-money-service-business-e-money-license-in-jersey-302768153.html](https://www.prnewswire.com/news-releases/bloomsbury-money-secures-money-service-business-e-money-license-in-jersey-302768153.html)retrieved 2026-09-08 - T2[https://www.jerseyfinance.com/ifc/business-directory/jfsc/](https://www.jerseyfinance.com/ifc/business-directory/jfsc/)retrieved 2026-09-08 - T4[https://payatlas.com/regulator/jfgb-4747](https://payatlas.com/regulator/jfgb-4747)retrieved 2026-09-08 - T3[https://thebanks.eu/articles/banks-in-the-Channel-Islands](https://thebanks.eu/articles/banks-in-the-Channel-Islands)retrieved 2026-09-08 ### W1bConduct, Safeguarding & PromotionsProbableconfirmed 2026-09-08▾# MSB and banking conduct is governed by JFSC Codes of Practice (MSB Code, Banking Code) issued under the FSJ Law and Banking Business (Jersey) Law 1991, requiring fair client communication, safeguarding of assets and adequate governance. Jersey has no statutory financial-promotions regime as detailed as the UK's; conduct rules sit within sector codes rather than a standalone promotions statute. Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason. no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1[https://www.jerseyfsc.org/industry/codes-of-practice/money-service-business-code-of-practice/](https://www.jerseyfsc.org/industry/codes-of-practice/money-service-business-code-of-practice/)retrieved 2026-09-08 - T1[https://www.jerseyfsc.org/industry/codes-of-practice/deposit-taking-business-code-of-practice-main-body-february-2024/](https://www.jerseyfsc.org/industry/codes-of-practice/deposit-taking-business-code-of-practice-main-body-february-2024/)retrieved 2026-09-08 - T1[https://www.jerseyfsc.org/industry/guidance-and-policy/jfsc-use-of-enforcement-powers/](https://www.jerseyfsc.org/industry/guidance-and-policy/jfsc-use-of-enforcement-powers/)retrieved 2026-09-08 - T3[https://www.bakerandpartners.com/insights/impact-of-the-2026-civil-penalty-changes-implemented-by-the-government-of-jersey](https://www.bakerandpartners.com/insights/impact-of-the-2026-civil-penalty-changes-implemented-by-the-government-of-jersey)retrieved 2026-09-08 - T3[https://www.comsuregroup.com/news/comsure-briefing-jersey-financial-services-commission-penalty-regime-updates-effective-12-march-2026/](https://www.comsuregroup.com/news/comsure-briefing-jersey-financial-services-commission-penalty-regime-updates-effective-12-march-2026/)retrieved 2026-09-08 ### W2Stablecoins & Digital Money1 gapProbableconfirmed 2026-09-08▾# Jersey has no bespoke stablecoin statute; stablecoins are treated as tokenised real-world assets under the JFSC's 2024 Guidance Note on Tokenisation of Real-World Assets, requiring full backing by low-risk/cash-equivalent assets, Jersey incorporation, COBO consent and AML compliance. Jersey launched its first stablecoin under this framework in 2025. Open gap — wpm-int-1 No stablecoin/e-money framework-specific delta for JE was located this cycle. no under-indexing note recorded No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass. no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1[https://www.jerseyfsc.org/industry/guidance-and-policy/tokenisation-of-real-world-assets-rwas/](https://www.jerseyfsc.org/industry/guidance-and-policy/tokenisation-of-real-world-assets-rwas/)retrieved 2026-09-08 - T3[https://charltonsquantum.com/jersey-virtual-assets-regulation/](https://charltonsquantum.com/jersey-virtual-assets-regulation/)retrieved 2026-09-08 - T4[https://rigorrank.com/jurisdictions/JERSEY](https://rigorrank.com/jurisdictions/JERSEY)retrieved 2026-09-08 - T3[https://www.ifcreview.com/articles/2024/february/jersey-regulation-of-the-virtual-assets-industry/](https://www.ifcreview.com/articles/2024/february/jersey-regulation-of-the-virtual-assets-industry/)retrieved 2026-09-08 - T4[https://en.innovando.news/jersey-accelera-su-fintech-e-tokenizzazione-asset/](https://en.innovando.news/jersey-accelera-su-fintech-e-tokenizzazione-asset/)retrieved 2026-09-08 ### W3Operational Resilience & Critical InfraProbableconfirmed 2026-09-08▾# Jersey's operational resilience posture is anchored in the JFSC's revised Outsourcing Policy (effective 1 January 2024), which requires notification and, for material arrangements, a 'no objection' from the JFSC for outsourcing including cloud, data-centre, cyber-security and digital-ID services. There is no standalone DORA-style resilience statute; resilience obligations sit within the outsourcing and codes-of-practice framework. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open its jurisdiction pages on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/) Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason. no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T1[https://www.jerseyfsc.org/industry/guidance-and-policy/outsourcing-policy/](https://www.jerseyfsc.org/industry/guidance-and-policy/outsourcing-policy/)retrieved 2026-09-08 - T3[https://www.careyolsen.com/insights/briefings/jfsc-revised-outsourcing-policy-practical-implications](https://www.careyolsen.com/insights/briefings/jfsc-revised-outsourcing-policy-practical-implications)retrieved 2026-09-08 - T1[https://www.jerseyfsc.org/industry/consultations/consultation-outsourcing-policy-no-6-june-2022/](https://www.jerseyfsc.org/industry/consultations/consultation-outsourcing-policy-no-6-june-2022/)retrieved 2026-09-08 - T1[https://www.jerseyfsc.org/publications/business-plans/business-plan-2020/our-four-year-strategic-roadmap/build-even-more-effective-supervision/](https://www.jerseyfsc.org/publications/business-plans/business-plan-2020/our-four-year-strategic-roadmap/build-even-more-effective-supervision/)retrieved 2026-09-08 ### W4Scheme & Network ComplianceProbableconfirmed 2026-09-08▾# Jersey does not operate a domestic card scheme or interchange-regulation statute; card acceptance in Jersey runs on UK/international acquirer and scheme infrastructure (Visa/Mastercard), with PCI DSS compliance enforced contractually by acquirers/schemes rather than by Jersey statute. Absent-field provenance recorded for a Jersey-specific interchange/surcharging law. Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason. no periodic updates on record for this sub-brief Evidence 1 Sources and findings (1) - T3[https://en.wikipedia.org/wiki/Payment_Card_Industry_Data_Security_Standard](https://en.wikipedia.org/wiki/Payment_Card_Industry_Data_Security_Standard)retrieved 2026-09-08 ### W5Payment Corridor Dynamics1 gapProbableconfirmed 2026-09-08▾# Jersey's principal payment corridor is with the UK (sterling, Faster Payments and CHAPS), reflecting its status as a Crown Dependency closely integrated with UK clearing and correspondent-banking infrastructure; cross-border/international flows rely on SWIFT and correspondent banks given Jersey's absence of direct scheme/clearing membership of its own. Open gap — wpm-int-2 No corridor dynamics delta for JE was located this cycle. no under-indexing note recorded No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass. no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T1[https://www.iomfsa.im/fsa-news/2026/jul/crown-dependencies-propose-coordinated-approach-to-app-fraud-framework](https://www.iomfsa.im/fsa-news/2026/jul/crown-dependencies-propose-coordinated-approach-to-app-fraud-framework)retrieved 2026-09-08 - T3[https://ciiom.barclays.com/our-locations/jersey/](https://ciiom.barclays.com/our-locations/jersey/)retrieved 2026-09-08 - T4[https://globalbanks.com/jersey-bank-account/](https://globalbanks.com/jersey-bank-account/)retrieved 2026-09-08 - T2[https://www.swift.com/payments/correspondent-banking](https://www.swift.com/payments/correspondent-banking)retrieved 2026-09-08 ### W6Industry Structure & Commerciallimited signalProbableconfirmed 2026-09-08▾# Jersey's Government is mid-way through a Financial Services Competitiveness Programme progressively repealing the Control of Borrowing (Jersey) Order 1958 regime; the COBO Amendment Order 2026 (in force 13 April 2026) and the Companies (General Provisions) and Companies Law amendment orders (in force 30 September 2026) have reduced consent requirements, with full repeal proposed from October 2026. Horizon · 2027 (± a year) Full COBO repeal Proposed · Tier 2 source Standing sub-brief · as of 11 October 2026 368 words · last cycle 2026-10-11 #### Industry Structure & Commercial Dynamics Jersey's Financial Services Competitiveness Programme produced two concrete legislative steps this cycle that together describe a sustained liberalisation of the island's corporate and capital-markets framework. The Control of Borrowing (Jersey) Amendment Order 2026 came into force on 13 April 2026 as the first legislative phase reducing the circumstances in which consent is required under the Control of Borrowing (Jersey) Order 1958, with the Government signalling this as part of a path toward full COBO repeal. The Companies (General Provisions) (Jersey) Amendment Order 2026, in force from 30 September 2026, removed the requirement for registrar consent on circulation of prospectuses outside Jersey, a direct reduction in the administrative friction facing issuers seeking cross-border capital-market access from the island. The Government's announcement on 1 October 2026 of proposed legislation to repeal the remaining Control of Borrowing requirements confirms that these two steps are not isolated administrative tidy-ups but phases of a single, deliberate programme. COBO has historically functioned as a consent-based gatekeeping mechanism over the raising and borrowing of capital and the circulation of offers to the public from Jersey; progressively narrowing its scope, and signalling intent to repeal it in full, is a structural liberalisation of market access for Jersey-domiciled and Jersey-administered capital-raising activity, including activity connected to payment-sector and fintech issuers using Jersey corporate structures. This liberalising direction should be read as a competitiveness measure aimed at reducing friction for legitimate cross-border capital flows, rather than as a weakening of prudential or AML standards; the COBO and prospectus-circulation changes are administrative-consent reforms operating independently of the island's customer due diligence and sanctions-implementation architecture, which has moved in a tightening rather than loosening direction over the same period. #### Outlook The proposed legislation to fully repeal the remaining Control of Borrowing (Jersey) Order 1958 requirements, announced 1 October 2026, is the development to track going forward; as of this cycle it remains a proposal rather than enacted law, and its passage and effective date should be treated as scheduled rather than confirmed until the relevant Order or Law is made. Firms using Jersey corporate vehicles for cross-border capital-raising, including payment-sector and fintech issuers, should expect continued incremental reduction in registrar-consent requirements as this programme proceeds. Read full sub-brief · 368 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T3[https://thebanks.eu/articles/banks-in-the-Channel-Islands](https://thebanks.eu/articles/banks-in-the-Channel-Islands)retrieved 2026-09-08 - T4[https://grokipedia.com/page/List_of_banks_in_Jersey](https://grokipedia.com/page/List_of_banks_in_Jersey)retrieved 2026-09-08 - T3[https://www.jerseyfinance.com/industry/focus/fintech/](https://www.jerseyfinance.com/industry/focus/fintech/)retrieved 2026-09-08 - T4[https://en.innovando.news/jersey-accelera-su-fintech-e-tokenizzazione-asset/](https://en.innovando.news/jersey-accelera-su-fintech-e-tokenizzazione-asset/)retrieved 2026-09-08 ### W7Legal & LitigationProbableconfirmed 2026-09-08▾# Jersey's Royal Court operates a mixed common/civil/customary law system; the standout payments-adjacent enforcement event is the Attorney General's first-ever Deferred Prosecution Agreement (DPA), against a foreign-exchange/cross-border payments firm, marking a new corporate-criminal-liability enforcement tool for Jersey financial services. Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason. no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T3[https://www.bedellcristin.com/knowledge/briefings/fy-2425/q2/key-points-for-regulated-financial-services-providers-from-jerseys-first-deferred-prosecution-agreement/](https://www.bedellcristin.com/knowledge/briefings/fy-2425/q2/key-points-for-regulated-financial-services-providers-from-jerseys-first-deferred-prosecution-agreement/)retrieved 2026-09-08 - T1[https://www.jerseyfsc.org/news-and-events/landmark-judgment-for-the-jfsc/](https://www.jerseyfsc.org/news-and-events/landmark-judgment-for-the-jfsc/)retrieved 2026-09-08 - T3[https://www.careyolsen.com/insights/briefings/jersey-litigation-guide-2026-chambers](https://www.careyolsen.com/insights/briefings/jersey-litigation-guide-2026-chambers)retrieved 2026-09-08 - T3[https://www.bakerandpartners.com/insights/foreign-and-domestic-enforcement-of-judgments-jersey](https://www.bakerandpartners.com/insights/foreign-and-domestic-enforcement-of-judgments-jersey)retrieved 2026-09-08 ### W8Merchant Acquiring & Risk1 gapUncertainconfirmed 2026-09-08▾# Jersey has no bespoke merchant-acquiring statute; card acquiring for Jersey merchants is provided by UK/international acquiring banks and PSPs operating under standard scheme rules and PCI DSS, supervised indirectly via JFSC MSB/banking licensing of the entities involved rather than an acquiring-specific regime. Absent-field provenance recorded for a Jersey-specific chargeback/dispute statute. Open gap — wpm-int-3 No merchant-acquiring delta for JE was located this cycle. no under-indexing note recorded No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass. no periodic updates on record for this sub-brief Evidence 1 Sources and findings (1) - T4[https://payatlas.com/regulator/jfgb-4747](https://payatlas.com/regulator/jfgb-4747)retrieved 2026-09-08 ### W9Product Innovation & Market DevelopmentProbableconfirmed 2026-09-08▾# Jersey pursues fintech innovation through 'Sandbox Jersey' (a collaboration of JFSC, Digital Jersey and Jersey Finance) rather than a formal regulatory sandbox; the JFSC is a member of the Global Financial Innovation Network (GFIN) and has issued sequential tokenisation/virtual-asset guidance (2016 VCE regulations, 2017 ICO guidance, 2024 RWA tokenisation guidance) as its principal product-innovation vehicle. Jersey does not operate an open-banking framework. Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason. no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T3[https://www.careyolsen.com/insights/briefings/jersey-fintech-guide-2025-chambers](https://www.careyolsen.com/insights/briefings/jersey-fintech-guide-2025-chambers)retrieved 2026-09-08 - T3[https://www.digital.je/jersey-for-fintech/](https://www.digital.je/jersey-for-fintech/)retrieved 2026-09-08 - T3[https://www.jerseyfinance.com/ifc/solutions/banking/](https://www.jerseyfinance.com/ifc/solutions/banking/)retrieved 2026-09-08 - T3[https://www.mondaq.com/jersey/fin-tech/1178906/fintech-2022](https://www.mondaq.com/jersey/fin-tech/1178906/fintech-2022)retrieved 2026-09-08 - T4[https://en.innovando.news/jersey-accelera-su-fintech-e-tokenizzazione-asset/](https://en.innovando.news/jersey-accelera-su-fintech-e-tokenizzazione-asset/)retrieved 2026-09-08 ### W10Consumer Protection & APP Fraudlimited signalProbableconfirmed 2026-09-08▾# Jersey has no standalone APP-fraud reimbursement statute; the JFSC is jointly developing, with the Guernsey and Isle of Man regulators, a coordinated Crown Dependencies APP fraud framework (high-level principles published July 2026) that explicitly diverges from the UK's mandatory PSR reimbursement regime by not implementing inter-bank cost-sharing, with detailed reimbursement/customer-responsibility rules still to be settled. Standing sub-brief · as of 11 October 2026 347 words · last cycle 2026-10-11 #### Consumer Protection & APP Fraud The Jersey Financial Services Commission, together with the Guernsey Financial Services Commission and the Isle of Man Financial Services Authority, published a joint Crown Dependencies Authorised Push Payment Fraud Framework statement on 7 July 2026. The framework sets out prevention measures, customer protection standards, reimbursement principles, treatment of gross negligence and consideration of customer vulnerability, and is initially scoped to sterling retail transactions processed via Faster Payments and CHAPS. The framework's most consequential feature is what it does not adopt: unlike the UK's Payment Systems Regulator regime, which mandates a fifty-fifty inter-bank cost-sharing mechanism for qualifying APP fraud reimbursement, the Crown Dependencies framework proposes no inter-bank cost-sharing mechanism at this stage. This is a deliberate divergence from the UK's approach rather than an omission, and it means consumer-reimbursement outcomes for APP fraud victims in Jersey may follow a materially different allocation of cost between the sending and receiving institutions than would apply for an equivalent transaction processed under the UK regime, even though both operate over the same sterling retail payment rails. Because the framework is scoped initially to sterling retail Faster Payments and CHAPS transactions, its reach does not yet extend to other payment rails or non-sterling transactions, which leaves open questions about how APP fraud occurring outside this initial scope will be treated. The joint publication by three Crown Dependency regulators signals a coordinated, cross-island approach to consumer protection standards distinct from, and lighter in its reimbursement architecture than, the UK's mandatory regime, reflecting a deliberate Crown Dependencies policy choice to diverge from UK practice on the specific question of inter-bank cost allocation. #### Outlook The framework's initial scope to sterling retail Faster Payments and CHAPS transactions, and its decision not to adopt inter-bank cost-sharing at this stage, are both described as a starting position rather than a final settlement; whether the Crown Dependencies regulators extend the framework's scope or revisit the cost-sharing question will be the practical test of how this policy choice performs as APP fraud patterns evolve. No committed timeline for any such extension was identified this cycle. Read full sub-brief · 347 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1[https://www.iomfsa.im/fsa-news/2026/jul/crown-dependencies-propose-coordinated-approach-to-app-fraud-framework](https://www.iomfsa.im/fsa-news/2026/jul/crown-dependencies-propose-coordinated-approach-to-app-fraud-framework)retrieved 2026-09-08 - T3[https://www.mondaq.com/jersey/financial-services/1815404/crown-dependencies-issue-app-fraud-framework](https://www.mondaq.com/jersey/financial-services/1815404/crown-dependencies-issue-app-fraud-framework)retrieved 2026-09-08 - T4[https://www.comsuregroup.com/news/crown-dependency-regulators-publish-high-level-principles-for-a-coordinated-app-fraud-framework/](https://www.comsuregroup.com/news/crown-dependency-regulators-publish-high-level-principles-for-a-coordinated-app-fraud-framework/)retrieved 2026-09-08 - T3[https://www.islandfm.com/news/jersey/pause-before-paying-to-avoid-being-scammed-islanders-urged/](https://www.islandfm.com/news/jersey/pause-before-paying-to-avoid-being-scammed-islanders-urged/)retrieved 2026-09-08 - T1[https://jrdca.org.je/jdcs](https://jrdca.org.je/jdcs)retrieved 2026-09-08 ### W11AML/CFT & Financial Crime (Sentinel.gi-fed)1 judgmentSourced from Sentinel.gi ↗Confirmedconfirmed 2026-09-08▾# Sentinel.gi position for Jersey: the AML/CFT/CPF regime rests on the Proceeds of Crime (Jersey) Law 1999, the Proceeds of Crime (Supervisory Bodies)(Jersey) Law 2008 and the Money Laundering (Jersey) Order 2008, consolidated in the JFSC's AML/CFT/CPF Handbook; MONEYVAL's July 2024 Mutual Evaluation Report found Jersey's effectiveness among the highest of jurisdictions evaluated, with a Recommended Actions plan being closed through 2026 and further follow-up reporting due December 2026. Key judgment — Probable · impact Jersey's financial crime compliance architecture is moving toward risk-based proportionality (reliance/MLCO reform) while the Crown Dependencies collectively diverge from UK/EU APP fraud cost-sharing norms, together signalling a jurisdiction prioritising calibrated, locally-tailored regulation over mechanical alignment with larger neighbours. claims: none recorded Standing sub-brief · as of 25 October 2026 534 words · last cycle 2026-10-25 #### AML/CFT & Financial Crime Jersey's financial crime control framework, which applies to payment companies and e-money institutions as regulated businesses alongside banks and other obliged entities, has been confirmed to change from 31 October 2026 when the remaining provisions of the Money Laundering (Jersey) Amendment Order 2026 take effect. The core change removes a fixed numerical threshold that previously determined when a firm was required to appoint a Money Laundering Compliance Officer, replacing it with a requirement that the firm itself conduct a risk-based assessment of whether an MLCO appointment is warranted. Alongside this, third-party reliance arrangements, under which one regulated firm may rely on customer due diligence already performed by another, are tightened, narrowing the circumstances in which a payment or e-money firm may depend on another entity's prior checks without independent verification. This matters specifically for non-bank payment institutions and electronic money institutions because the prior numerical-threshold approach gave these firms, which often operate with smaller compliance teams than bank-affiliated payment providers, a clear and mechanical answer to whether dedicated AML governance capacity was mandatory. Under the amended regime, that answer now depends on a risk assessment the firm itself must conduct and document, shifting a portion of the compliance burden from rule-following to risk-judgment and record-keeping. The reform applies across the regulated population without distinguishing bank-affiliated payment service providers from standalone non-bank payment institutions and e-money issuers; the governance obligation attaches to the firm's regulated activity rather than to its institutional form, so the practical effect on documentation and internal risk-assessment processes is materially the same whichever type of licence the firm holds. The tightening of third-party reliance arrangements has a distinct operational relevance for payment and e-money firms that participate in group structures or distribution partnerships where customer due diligence has historically been conducted once at the group or partner level and then relied upon by affiliated or downstream entities. A narrower reliance standard means some payment and e-money firms that previously depended on due diligence performed elsewhere in a corporate group or partner network will need to either conduct independent verification themselves or satisfy a higher bar for continuing to rely on another entity's checks. This development is sourced from Jersey's financial-crime compliance architecture generally, surfaced here because of its direct application to payment companies and e-money institutions as obliged entities under the amended order, rather than from any payments-specific rulemaking or scheme-level change. No new illicit-finance typology or enforcement finding specific to payments is identified in connection with this reform; the signal is the change to the governance and due-diligence framework payment and e-money firms operate under. #### Outlook The 31 October 2026 commencement date is the point at which payment and e-money institutions licensed in Jersey will need to have completed and documented the risk-based assessment that now determines MLCO appointment, and at which the tightened reliance standard becomes operative for any firm whose onboarding or due diligence processes depended on reliance arrangements with another regulated entity. Firms that previously sat just below the old numerical threshold are the population most likely to need to newly document a risk assessment where none was previously required, and this is the practical area worth monitoring as the provisions bed in. Read full sub-brief · 534 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T3sentinel.ogier.com/news-and-insights/insights/private-trust-companies-single-family-offices-and-governance-entities-registering-for-aml-supervision-under-jerseys-proceeds-of-crime-legislation/ - T?FIM (sentinel.gi) per-JID baseline profile — Jersey — Jersey runs an autonomous AML/CFT/CPF regime under the Proceeds of Crime (Jersey) Law 1999, Money Laundering (Jersey) Order 2008 and Sanctions and Asset-Freezing (Jersey) Law 2019 (SAFL), supervised by the JFSC with an operationally independent FIU (Jersey) since July 2023. Sanctions are incorporated ambulatorily from UK OFSI designations. Not EU/EEA-bound; no AMLR/AMLA application. - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: sourcing-thinness - T1FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-003) — Sanctions: UK wind-down - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: legal-gap ### W12Correspondent Banking, Settlement & Access1 gapProbableconfirmed 2026-09-08▾# Jersey banks (predominantly branches/subsidiaries of major international groups) rely on UK and international correspondent relationships and SWIFT for cross-border settlement access; deposit protection sits with the Jersey Bank Depositors Compensation Scheme, whose administration transferred from the Jersey Bank Depositors Compensation Board to the new Jersey Resolution and Depositors Compensation Authority (JRDCA) on 1 April 2026 under the Bank (Recovery, Resolution and Depositors' Compensation)(Jersey) Law 2017. Open gap — wpm-int-4 No sources located for Correspondent Banking, Settlement & Access (W12) developments in Jersey this cycle. no under-indexing note recorded No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass. no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1[https://www.jerseylaw.je/laws/current/l_10_2017](https://www.jerseylaw.je/laws/current/l_10_2017)retrieved 2026-09-08 - T1[https://www.gov.je/Government/Departments/Economy/Pages/FinancialServicesUnit.aspx](https://www.gov.je/Government/Departments/Economy/Pages/FinancialServicesUnit.aspx)retrieved 2026-09-08 - T1[https://jrdca.org.je/jdcs](https://jrdca.org.je/jdcs)retrieved 2026-09-08 - T2[https://www.swift.com/payments/correspondent-banking](https://www.swift.com/payments/correspondent-banking)retrieved 2026-09-08 - T4[https://globalbanks.com/channel-islands-offshore-banks/](https://globalbanks.com/channel-islands-offshore-banks/)retrieved 2026-09-08 ### W13Commercial Intelligence (M&A, Investment & Product)limited signalProbableconfirmed 2026-09-08▾# The clearest trailing-12-month commercial event identified for Jersey payments is the May 2026 grant of an MSB e-money/money-transmission licence to a digital banking division (Bloomsbury Money / DMALINK Jersey Limited), expanding multi-currency IBAN and cross-border payments capability from a Jersey base. Broader Jersey-specific payments M&A/funding disclosures were not found in this pass; absent-field provenance recorded for a dedicated Jersey payments-company funding round in the trailing 12 months. Standing sub-brief · as of 11 October 2026 251 words · last cycle 2026-10-11 #### Commercial Intelligence & Fintech Two discrete commercial events touched Jersey-domiciled or Jersey-regulated firms in the digital-asset space this cycle. CoinShares PLC, incorporated in Jersey, Channel Islands, listed its shares on the Nasdaq on 1 April 2026, a completed listing event confirmed by the company's own investor-relations materials. The listing was not publicly disclosed with an accompanying capital-raise amount in the sources available this cycle, so the commercial scale of the event beyond the listing itself is not publicly disclosed here. Separately, Komainu (Jersey) Limited completed the Virtual Assets Regulatory Authority's full operating-licence process in Dubai, a licensing-agreement-type event bringing together Komainu, Nomura, CoinShares and Ledger as partners, while Komainu continues to be headquartered and regulated by the Jersey Financial Services Commission. This is a specific, discrete commercial-regulatory event — a named firm obtaining a named licence in a named jurisdiction — distinct from any broader structural trend in digital-asset market access; no value for the arrangement was publicly disclosed in the sources reviewed this cycle. Both events point to a pattern of Jersey-domiciled or Jersey-regulated financial-innovation firms pursuing international market access and public-market capital routes while retaining their Jersey regulatory base, rather than relocating regulatory domicile alongside commercial expansion. #### Outlook No further disclosed commercial events for Jersey-domiciled payments or digital-asset firms were identified this cycle beyond the CoinShares listing and the Komainu Dubai licensing arrangement. Continued tracking of whether either firm discloses further transaction values or expands its regulatory footprint beyond Jersey and Dubai respectively is the relevant marker going forward. Read full sub-brief · 251 words no periodic updates on record for this sub-brief Evidence 1 Sources and findings (1) - T3[https://www.prnewswire.com/news-releases/bloomsbury-money-secures-money-service-business-e-money-license-in-jersey-302768153.html](https://www.prnewswire.com/news-releases/bloomsbury-money-secures-money-service-business-e-money-license-in-jersey-302768153.html)retrieved 2026-09-08 No modules match. Filters combine as OR inside a group and AND across groups. Reset all filters ## Provenance and declared absence Disclosure model: module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is. 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