The Money Laundering (Jersey) Order 2008 is a central piece of secondary legislation underpinning Jersey’s anti-money laundering and countering the financing of terrorism regime. It operationalises the provisions of the Proceeds of Crime (Jersey) Law 1999, including through direct references to FATF standards. Although it does not define WTR obligations as its primary focus, the Order creates the mechanisms by which the requirements of the FATF Travel Rule are enforced for both traditional and digital fund transfers, particularly via customer due diligence, record-keeping, and reporting procedures.

Customer Due Diligence & Identification Measures

Articles 3 and 13 establish the requirement for customer due diligence (CDD) before a business relationship begins or a one-off transaction is conducted. Identification must cover customers, beneficial owners, third parties on whose behalf customers are acting, and any legal arrangements such as trusts. The Order explicitly references the need to understand source of funds and to update CDD documentation regularly, especially in higher-risk scenarios. This provides a foundation for wire transfer compliance by ensuring that both originator and beneficiary identities are verified and recorded.

Article 4 defines one-off transactions and sets lower thresholds for value transfer services and virtual currency exchange businesses, starting at 1,000 euros. This aligns with FATF expectations for traceability in cross-border wire transfers, including those involving digital assets.

Enhanced Due Diligence & Risk Assessment

Articles 15 to 15B require enhanced due diligence (EDD) in higher-risk cases, including transactions involving politically exposed persons, cross-border correspondent banking, and dealings with enhanced risk jurisdictions. For wire transfers, this ensures increased scrutiny over transactions that may otherwise lack transparency. Article 15B, in particular, sets out additional safeguards for Jersey financial institutions and virtual asset service providers entering into correspondent relationships with foreign institutions. It obliges firms to understand the nature of their counterpart’s business, assess supervisory quality, and confirm equivalency of AML/CFT controls.

Record Keeping & Transaction Monitoring

Articles 19 and 20 specify the obligation to keep records of identity documentation and all transaction data for a minimum of five years. These must be retained in a manner that allows immediate access by the Financial Intelligence Unit (FIU), the Jersey Financial Services Commission, or law enforcement. This directly supports the goals of the Travel Rule by ensuring that both the originator and beneficiary information associated with transfers is stored, retrievable, and capable of being audited.

Ongoing monitoring, as defined in Article 3(3), requires scrutiny of transactional behaviour to detect anomalies or inconsistencies. This further enhances the transparency and accountability of payment flows, especially in wire transfer chains.

Reporting & Disclosure Requirements

Articles 21 to 23 of the Order govern the internal reporting of suspicious activity. Relevant persons must establish procedures to ensure that all staff are able to escalate concerns internally to a designated or reporting officer. If the officer determines that there is knowledge or suspicion of money laundering, the information must be disclosed to the FIU. This reporting framework plays a critical role in wire transfer regulation, particularly when originator or beneficiary information is missing or inconsistent with the customer’s profile.

Disclosures to the FIU must be made in a prescribed form and supported by any further information requested. Article 23 requires regulatory and enforcement bodies to share information with the FIU when evidence of money laundering arises, further reinforcing Jersey’s supervisory capacity over wire transfer activity.

Restrictions on Shell Banks & Anonymous Accounts

Article 23A prohibits Jersey financial institutions and VASPs from maintaining correspondent relationships with shell banks or with institutions that permit such use. Article 23B expressly forbids the opening of anonymous or fictitious accounts. These measures are essential complements to the Travel Rule, ensuring that all accounts involved in wire transfers are linked to verified legal or natural persons.

Exemptions & Equivalence

The Order includes narrowly defined exemptions under Articles 17 to 18, based on low-risk factors such as regulated counterparties, public authorities, and certain insurance policies. It also permits reliance on third parties or financial group affiliates where equivalent standards are in place. These provisions provide regulatory flexibility while maintaining the underlying integrity of WTR principles.

Conclusion: WTR Compliance Integration

The Money Laundering (Jersey) Order 2008 provides the procedural and operational foundation for implementing Wire Transfer Regulation across Jersey’s financial sector. By embedding rigorous identity verification, record-keeping, ongoing monitoring, and reporting obligations, the Order ensures full alignment with FATF Recommendation 16. It applies equally to traditional financial institutions and virtual asset service providers, ensuring that all transfers—regardless of format—are accompanied by transparent, traceable originator and beneficiary data. In doing so, Jersey affirms its commitment to international financial crime prevention standards and reinforces the robustness of its cross-border transfer ecosystem.