Proposed Improvements to Jersey’s Sound Business Practice Policy

The SBPP identifies ‘sensitive activities’ and requires additional information or scrutiny for related applications submitted under the Control of Borrowing (Jersey) Order 1958 before the Jersey Financial Services Commission (the “JFSC”) consents to such applications. The Codes of Practice for investment business, fund services business, certified funds and trust company business all require registered persons to have due regard to the SBPP.

Following a consultation period that closed on 6 August 2025, the JFSC is now carefully considering feedback received on the draft Sound Business Practice Policy, jointly developed by the Government of Jersey and the JFSC. The SBPP framework is intended to identify and manage activities that may pose reputational risks to Jersey’s financial and commercial integrity, such as those involving high-risk jurisdictions, controversial sectors, or complex ownership structures. The proposed amendments are expected to simplify the SBPP’s scope of application, reducing potential business frictions and delays.

Key proposed changes include:

• Improved clarity and accessibility: general updates to the wording of the SBPP.
• Removal of Table 1: the Jersey Companies Registry will continue to require information on applications where regulated financial services activity is proposed.
• Revision of Table 2: to modernise the SBPP and align with current international standards and risk considerations, including a new category for activities involving FATF blacklist and suspended members. This new category is proposed to replace the ‘Russia statement’.

These policy changes are anticipated to take some time to be fully implemented. Maples Group will continue to monitor and advise on developments in this space as interim arrangements are published. Please reach out if you have any questions on this topic or for general regulatory compliance advice.

For more on the enhancements to Jersey’s financial services offering, visit our post on Amendments to the Jersey Private Fund Guide 2025.