CDD on Clubs and Societies in Jersey and elsewhere Clubs and societies There is a wide variety of clubs and societies, ranging from large, nationally and internationally active organisations subject to a high degree of public interest and quasi-accountability, to small, local clubs and societies funded by small, individual donations or subscriptions from local communities, […]Read More
Help! I’m a MLRO!
Help Im a MLRO – SUSPICIONS AND TIPPING OFF In Jersey
After talking to a client today I have put together a summary of recent changes to the ‘tipping-off’ offence under Jersey law PROCEEDS OF CRIME AND TERRORISM (TIPPING OFF – EXCEPTIONS) (JERSEY) REGULATIONS 2014 – Revised Edition https://www.jerseylaw.je/laws/revised/Pages/08.780.80.aspx Please note this update is only intended to give a summary and general overview of the subject […]Read More
HELP IM AN MLRO/MLCO, get me out of here…..!!
Comsure will start posting typical questions and answers to assist those charged with keeping their firms out of trouble….. Question – Please, can you help me persuade my company to beef up its Transaction profiles? Answer – To help make a case to the company an MLCOs first port of call should be the JFSCs […]Read More
Guernsey MLROS – Lessons from the prosecution of an MLRO
In anticipation of Comsure’s up and coming Guernsey training event “To Report Or Not To Report, That Is The Question?” on the 8th December at the Old Government House (Time: 12.00 – 14.15 (registration 11.45 am)) CLICK HERE) the following thoughts set the scene for the matters to be discussed The workshop follows the recent […]Read More
Damned if I do, damned if I don’t – who would be a MLRO? – Jersey – 3rd September 2015
03/09/15 – Pictures from Damned if I do, damned if I don’t – who would be a MLRO? – Jersey Many thanks to all of you who came down today to get an understanding of the risks involved of being an MLRO and what you should do to protect yourself in the light of recent court […]Read More
MLROs and Directors can take a breath and sleep easier
On the 26th June STM Fiduciaire’s former employees and STM Fiduciaire win court case against the prosecution of failing to report. Comsure were in court throughout the proceedings and will be updating all its clients on the key issues. Comsure will also be posting further updates as and when our notes are typed up!!! Comsure’s […]Read More
Help! I’m a new MLRO: Am I suspicious?
Help! I’m a new MLRO: Am I suspicious? 22 Oct 2012 In your previous roles, you may have made internal reports about transactions to your money laundering reporting officer (MLRO), or even helped with making reports to SOCA as a deputy MLRO. However, now that you are the MLRO, the buck stops with you to […]Read More
Help! I’m a new MLRO – Due diligence
Help! I’m a new MLRO – Due diligence – You should consider auditing your procedures in relation to due diligence and whether they are actually being followed. Some questions you may wish to consider include: Have you identified the areas in which due diligence investigations are required? If you allow exemptions for due diligence, are […]Read More