Jersey's implementation of Recommendation 16 (R.16) was rated as Largely Compliant in the 2024 Mutual Evaluation Report. While the jurisdiction has incorporated core wire transfer obligations into its legal and regulatory framework, there remain notable technical gaps that affect full alignment with the FATF standard.

Scope Limitations

One primary shortcoming is that wire transfers equal to or below EUR 1,000 are not covered by the relevant regulation. This means certain low-value transactions are excluded from the traceability and transparency requirements under R.16, weakening the reach of anti-money laundering (AML) safeguards where small transactions may still be used to obscure illicit activity.

Suspicious Transaction Reporting

Another significant deficiency relates to money or value transfer service (MVTS) providers. Jersey does not require these entities to file suspicious activity reports (SARs) in every jurisdiction affected by a suspicious cross-border wire transfer. Nor must they make the corresponding transaction data available to the financial intelligence unit (FIU) in all such jurisdictions. This impairs the effectiveness of multi-jurisdictional information-sharing and enforcement against potential terrorist financing or money laundering channels.

Conclusion

Jersey has made considerable progress in aligning with Recommendation 16 but needs to close specific gaps related to transaction thresholds and the obligations of MVTS providers in cross-border contexts. Addressing these issues would enhance the jurisdiction’s ability to ensure the traceability of wire transfers and reinforce the integrity of its AML/CFT regime.