Compliance function: Key Persons regime

 

It is the policy of the JFSC to make the content of all responses available for public inspection, including the names of respondents, unless respondent requests for anonymity.

Name (optional):

 

1. Email (optional):

 

2. Company (optional):

 

3. Industry (optional):

 

4. Please rank the options in order of preference, with 1 being your preferred option, and 4 being you least preferred option.

Drag the options into your desired order, or use the drop down lists: *

 

5. How would you propose we improve the status quo - retaining both the residency and employment requirements? Please explain your reasons and what improvements, if any, you consider appropriate. In your response, please consider the following: 

  • How would the proposed option address the challenge in recruiting and retaining Key Persons?
  • How would the proposed option benefit the financial services industry in Jersey?
  • What effect would the proposed option have on Jersey’s compliance with FATF standards?
  • The risks associated with these enhancements, and how they might be mitigated
*

 

6. What are the risks of removing the Jersey residency requirement? How would you propose that these risks be mitigated? Please explain your reasons. In your response, please consider the following: 

  • How would the proposed option address the challenge in recruiting and retaining Key Persons?
  • How would the proposed option benefit the financial services industry in Jersey?
  • What effect would the proposed option have on Jersey’s compliance with FATF standards?
*

 

7. What are the risks of removing the employment requirement? How would you propose that these risks be mitigated? Please explain your reasons. In your response, please consider the following:  

  • How would the proposed option address the challenge in recruiting and retaining Key Persons?
  • How would the proposed option benefit the financial services industry in Jersey?
  • What effect would the proposed option have on Jersey’s compliance with FATF standards?
*

 

8. What is your experience with the use of RegTech and do you agree it could be a solution for lessening the human capital burden for the compliance function? In your response, please consider the following:

  • Do you agree that RegTech is useful in addressing the challenge in recruiting and retaining Key Persons?
  • The risks associated with RegTech and how they might be mitigated.
*

 

9. Is there an alternative solution or anything else that we have not considered in the paper? In your response, please give reasons to support your answer if not covered in other question responses.