Sector-based aggregated data

The data in these reports covers 2019 - 2023 and provides a general overview of each sector along with trends on inherent risk factors such as customers from higher risk jurisdictions and politically exposed persons (PEP) connections.

The aim of publishing these reports is to improve the understanding of money laundering and terrorist financing risk within each sector and enable a comparison across different sectors and activities. Key risk indicators are included for each sector to provide useful benchmarking for supervised persons looking to assess their own money laundering and terrorist financing risks.

The reports are not risk assessments. An explanation has been provided to support the aggregated data presented through a combination of graphs and tables. Whilst some data quality and integrity checks are performed on receipt of the data, we rely on the accuracy and completeness of data provided by industry.

We will be engaging with industry through trade bodies and associations during Q1 2025 to gather feedback and inform future publications

Funds sector

Similarly to the trust company business (TCB) sector, Jersey has a significant funds sector which has a similar geographical reach: 168 jurisdictions compared to the 171 reported by the TCB sector. Jersey offers collective investment funds (CIFs) and private fund products with the current primary target market being professional investors. The principal activity undertaken by Fund Services Businesses (FSB) is the provision of fund administration and management services. The JPF continues to be the growth product in terms of the number of funds however CIFs continue to dominate the number of investors and assets under management.

In 2023, 13.6% of CIF investors/beneficial owners are reported as resident in a higher-risk jurisdictions with the vast majority of these being from South Africa (12.9%), which was added to the FATF Grey List in February 2023. Except for South Africa only a small percentage of both CIF and JPF total investors/beneficial owners are from higher risk jurisdictions. The number of fund investors/beneficial owners reported as resident in one of the terrorist financing jurisdictions of interest is very low for both CIFs and JPFs with both trending down across the reporting period 2019 -2023.

The number of reported connections to politically exposed persons (PEPs) has increased in both CIFs and JPFs. However, when considered as a percentage of total reported investors/beneficial owners the CIFs trend is increasing whilst the JPFs is decreasing. PEPs are not evenly distributed through the CIFs and JPFs, in 2023:

JPFs

• 38% of JPFs reported one or more PEP connections
• 70% of the PEP connections by number reported by 10% of the JPFs

 CIFs

• 48% of CIFs reported one or more PEP connections
• 76% of the PEP connections by number reported by 10% of the CIFs

CIFs:

Certified/Recognized Funds: A CIF granted a certificate or permit by the JFSC with collective investment of capital by way of public offer. Provided services by an FSB.

Unregulated Funds: A CIF that meets, and continues to meet, the eligibility criteria of the Collective Investment Funds Unregulated Funds (Jersey) Order 2008. Provided services by an FSB.

Private funds:

Jersey Private Funds (JPFs): A private fund vehicle launched in April 2017. Must be offered to a restricted circle of persons which must not be retail investors and must always have 50 or fewer offers/investors. Provided services by a Designated Service Provider (DSP).

Legacy Private Funds: Prior to April 2017 there were various types of private funds, collectively known as the Legacy Private Funds. This comprises: COBO-only Fund, Private Placement Fund, and Very Private Fund. These could not be established after April 2017.

Read our data report for the funds sector. 

Accountancy sector

The supervised persons that comprise the sector vary significantly in terms of size, geographic reach, client profiles and the services provided. The sector includes the Big 4 accountancy firms which have an international reach through to sole traders which have a predominately domestic focus and account for nearly 40% of the sector. Overall, the sector is small; less than 4.5% of the total financial services sector revenue with the Big 4 accountancy firms dominating – generate approximately 66% of the reported income and employ nearly 60% of the reported staff. According to the data collected tax advice is the most common service provided, followed by accountancy services, audit and insolvency.

Data collected in respect of the residency of the sector’s customers demonstrates that in 2023 over 77% of all customers are Jersey residents with a further 10% residing in the United Kingdom. Exposure to higher risk jurisdictions is relatively low and, as with other sectors, the higher risk jurisdictions with the greatest number of reported customer relationships are South Africa followed by Monaco.  Connections to terrorist financing jurisdictions of interest is very low.

The level of PEP connections is similar to the legal sector with 4.4% of the reported customer relationships including a PEP connection as against 4.1% in the legal sector. Overall, PEP connections are greatest where the customer is a company.

The key risk indicators have been split between larger firms with 50 or more employees, smaller firms with fewer than 50 employees and sole traders. This split acknowledges that these may have different risk profiles due to their customer focus. The data demonstrates that the larger firms are more likely to have higher risk customers and PEPs but conversely are also more likely to have applied enhanced customer due diligence. 

Read our data report for the accountancy sector. 

Estate agent sector

The estate agency sector in Jersey comprises those involved in the buying or selling of property. The property may be residential or commercial; freehold (including flying freehold) or leasehold property; share transfer; Jersey or non-Jersey based. The sector does not include those selling new build properties “off plan” nor the activity of managing properties including lettings.

In 2023, Jersey resident individuals represented just over 89% of the reported customers with Jersey companies representing nearly another 8%. The small number of non-Jersey resident customers (approx. 3%) almost entirely comprises customers from the UK and Guernsey.

Overall, the data highlights that the majority of transactions relate to residential Jersey property which is freehold, flying freehold or leasehold rather than share transfer. Given the profile of the transactions combined with the customers completing one-off transactions rather than entering into business relationships the year-on-year trend reflects the buoyancy, or otherwise, of the Jersey housing market. In 2023, the data shows a substantial reduction in the number of sales which is consistent with data reported by the legal sector and the housing market statistics published by the government of Jersey.

Read our data report for the estate agent sector. 

Lending sector

In addition to banks Jersey supports other firms that grant loans, mostly to the local population. The lenders (non-bank) report includes data from these lenders i.e. it excludes lending by any person also registered with the JFSC under another regulatory law such as deposit takers (banks).

This population of lenders is varied including large and small businesses where some are actively lending, and others have a loan book in run off. The nature of the lending activities includes personal/consumer loans (including vehicle finance), asset backed finance, as well as business loans and property lending, including mortgages and bridging finance. Consumer lending is mostly short term (1-5 years) and unsecured (except for vehicle loans and mortgages).

The total amounts lent by this sector are significantly lower than the value of loans made by the banks (see data report for banks published December 2024). In 2023, approximately 93% of the customers were reported by just over 21% of the reporting entities; just over 92% of the customers were reported as individuals; and nearly 73% of the customers/beneficial owners were reported as being Jersey resident (in total 99.7% of the customers/beneficial owners are reported as resident in the UK or a Crown Dependencies).

Read our data report for the lender sector. 

Banking sector

The banking sector in Jersey is relatively stable in terms of the number of licenced entities, employees, and the total number of customer relationships. Total deposits have steadily increased from £113bn in 2016 to £156bn at the end of 2023.  

The data collected relates to both deposit-taking and bank lending. It highlights the global reach of the sector with customers or beneficial owners of customers reported in 206 jurisdictions and 62% of deposit customers being resident outside of Jersey. Over the period analysed, exposure to higher risk jurisdictions has been impacted by changes to the FATF list of jurisdictions identified as having strategic deficiencies. In particular, South Africa was added to the FATF “grey list” in February 2023 - a jurisdiction which ranks 6th in terms of the residency of deposit customers.  

The number of banking customers who are, or are connected to, a politically exposed person (PEP) has steadily grown since 2019. In September 2023, the Money Laundering (Jersey) Order 2008 was amended to allow for the declassification of PEPs. In 2023, 5 of the 19 banks which provided data had declassified one or more PEPs. 

The key risk indicators have been split between banks with a high street presence in Jersey (retail banks) and banks which primarily provide corporate banking solutions (corporate banks). This split acknowledges that these banks may have different risk profiles due to their customer focus. The data demonstrates that customers of corporate banks are more concentrated in higher risk jurisdictions, are more likely to be connected to a PEP and are rated as higher risk by the banks compared to retail bank customers. 

Read our data report for the banking sector. 

Trust company business sector

Jersey has a large and significant trust company business (TCB) sector directly employing nearly 5,000 individuals and with a geographical reach that is second only to the banking sector. In December 2024, the JFSC website listed 776 persons registered to carry on TCB activity, including natural persons and participating members. 

The data demonstrates the international nature of Jersey’s TCB sector with customers reported from 171 different jurisdictions and the vast majority of customers reported as being resident outside Jersey. In 2023, 7.8% of TCB reported non-Jersey customer relationships are from higher risk jurisdictions with just under half of these from South Africa (3.4%). Other prominent higher risk jurisdictions include Kenya (1.0%), Monaco (0.9%), Lebanon (0.9%), and Russia (0.3%).  

The proportion of customers from terrorist financing higher risk jurisdictions has decreased from 2.4% in 2021 to 1.6% in 2023 due primarily to a reduction in Russian customers. 

Based on 2023 data, the TCB sector has the highest level of PEP connections when considered against the total number of reported customer relationships (14.7%) with the total number of PEP connections steadily increasing throughout the reporting period.  

The data demonstrates that enhanced customer due diligence (CDD) has been applied for 60% of customer relationships reflecting the sector’s conservative approach to onboarding new customers. 

The sector offers a full range of trust and company activities with management services being the activity reported as most often provided to customers. Whilst management services activity represents 67.5% of the reported activity in 2023 this is a decrease from the high in 2020 (75%). Over the same period there has been a rise in the provision of trustee-only service.  

Read our data report for the trust company business sector. 

Legal sector

The legal sector data covers law firms registered with us, which vary significantly in terms of size, geographic reach, client profiles and the services provided. Some law firms are involved in large multi-national transactions, where they often play a discrete role, and others have a customer base which is predominately domestic.  

Given the one-off transactional nature of some legal services, year on year trends can be less stable than other sectors but provide useful insights regarding the risks within the sector.  

Data collected in respect of the residency of the law firm’s customers demonstrates that in 2023 half of all customers are Jersey residents with a further 22% of customers residing in the United Kingdom. Exposure to higher risk jurisdictions is stable and relatively low compared to some other financial services sectors in Jersey. As with other sectors analysed, the higher risk jurisdiction with the greatest number of customer relationships is South Africa, followed by Monaco and Lebanon.  

4.1% of the law firm’s customer relationships include a PEP connection. This is highest for Jersey vehicles such as limited partnerships (16.6%) followed by Trusts with a non-Jersey trustee (10.7%) and trusts with a Jersey trustee (9.2%). PEP exposure is highest among larger law firms where the provision of services to trusts, companies and other legal arrangements is more common. 

The data shows a reduction in 2023 in the number of matters relating to the buying and selling of immovable property/business entities, which is consistent with data published by Statistics Jersey demonstrating a reduction in Jersey property sales in 2023. 

Read our data report for the legal sector. 

Investment business sector

The activity of investment business (IB) is undertaken by a diverse range of businesses, including local independent financial advisers (IFAs), niche wealth managers and banks with a global presence.  

IB is divided into 5 “classes” (A, B, C, D and E) with this reporting focusing on classes A – D, class E being rarely used. These include dealing in investments (Class A), managing investments (Class B), giving investment advice when not prevented from holding client (Class C) and giving investment advice when prevented from holding client assets (Class D).  

Over the period 2019 to 2023 the value of total assets under administration (or equivalent measure) peaked in 2021 but has generally grown with the total assets under administration, in custody, managed or advised increasing from £121bn in 2019 to £137bn in 2023. This includes significant growth in the value of assets advised by Class D entities, which have increased from £3.9bn in 2019 to £11.3bn in 2023. Over the same period, the number of firms has declined due to a combination of banks ceasing to operate in Jersey as well as consolidation of non-bank IBs within the sector.  

Much of the data analysed has been split between banks which provide IB services and non-bank IBs. This demonstrates that, in general, banks have a greater proportion of customers from higher risk jurisdictions, more connections to politically exposed persons and consider their customers to be higher risk for ML/TF. This increased inherent risk may be partially mitigated by the heightened levels of enhanced CDD applied to banks’ IB customers in comparison to non-bank IBs.   

Read our data report for the investment business sector.