The Jersey Financial Services Commission (JFSC) is currently involved in two heavily interlinked projects requiring the submission of risk data from Industry; (i) the JFSC Supervisory Risk Data Collection Exercise (risk data exercise) and the National Risk Assessment (NRA). To be clear risk data will be captured once and used in two projects.
The risk data exercise is collecting data that will be used by the JFSC to understand and assess risk, including money laundering and terrorist financing, at the individual entity and sector level. Phase I of the risk data exercise was recently completed, and the data is now being analysed. During the week commencing 2 July 2018, Phase II of the risk data exercise will commence, and a new data request will be issued utilising the same JFSC Portal technology used to collect Phase I data. The Phase II risk data is required to be returned by 7 September 2018.
The data collected under both Phases of the risk data exercise will be anonymised, aggregated and used in the Island-wide NRA which seeks to identify, assess and understand the money laundering and terrorist financing risks in Jersey such that the regulatory framework is risk based and commensurate with the identified risks.
Unlike Phase I however, the request for the supply of the information required under Phase II will not be done under legislative Notice. Instead, the request for the supply of the information required under Phase II will be issued in accordance with the JFSC’s general powers (Article 8 of the Financial Services Commission (Jersey) Law 1998 and Article 8 of the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008).
The difference in approach for Phase II is in recognition of the fact that the data requested under Phase II is a more extensive data set which should be held by Industry but may not be readily available. On this basis, it is being requested on a ‘best endeavours’ basis.
Prior to issuing the Phase II risk data request, the JFSC would welcome Industry’s feedback on the content of the Excel workbooks containing the Phase II risk data questions. On this basis, please see attached the draft workbooks that have been prepared for all of the relevant sectors. Focusing only on those sectors relevant to you, we should be grateful if you would kindly review the same and provide us with your comments. In particular, the JFSC is keen to receive Industry’s views on the following:
› Are the questions easy to understand? If not, please suggest additional/different wording that would aid clarification.
› Where drop down menus for answers are included, is their use appropriate? Are different/additional answers required?
› Should further questions be included?
› Are there any errors/problems with the functionality of the Excel workbooks themselves (e.g. drop down menus)?
› Is what the JFSC is asking for in the timeframe achievable?
Whilst the workbooks include spaces for 2018, respondents are not expected to predict the future. Data will be collected as at 31 December 2016 and 2017 (depending on the question), and then again next year as at 31 December 2018.
The guidance that will accompany the workbooks is not yet ready for circulation however if, after having read the questions, you consider there to be any areas that will require specific guidance, we would be pleased to hear from you.
All feedback should be submitted to the JFSC to the following address SupervisoryRiskUnit@jerseyfsc.org on or before the 25 June 2018.
The JFSC is grateful for your assistance in this regard.
Please find below links to the draft spreadsheets:
Draft Risk Data Collection FSB
Draft Risk Data Collection Funds
Draft Risk Data Collection Managed Entities
Draft Risk Data Collection TCB Banking IB
Draft Risk Data Collection
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