Adjusting the scope of Schedule 2

Schedule 2 recast

In January 2023, Schedule 2 of the Proceeds of Crime (Jersey) Law 1999 (Schedule 2) was recast such that scope exemptions were removed, definitions were aligned with FATF Standards and the scope of Jersey's anti-money laundering (AML) legal and regulatory framework was significantly expanded. Our detailed explanation of the changes that were introduced can be found here. 

Since the recast of Schedule 2 in 2023, industry has grappled with requirements and obligations for those that found themselves in scope of the AML framework and in some areas, ambiguity as to exactly which activities and operations are deemed to be in scope.

Financial Services Competitiveness Programme

The Financial Services Competitiveness Programme was launched in April 2025, which is a collaborative effort involving teams across Government of Jersey departments, Jersey Finance, the Jersey Financial Services Commission (JFSC) and others, with the aim of strengthening Jersey's position as a leading international finance centre. 

"Workstream 2" of the programme is aimed at delivering quick impact improvements to the business and regulatory environment. The primary output of this workstream will be a focussed list of priority actions which can be implemented within the next 12 months to improve the regulatory environment and ease of doing business in Jersey, while preparing for longer-term improvements. In feedback that Government has received from industry to date, we are aware that Schedule 2 came up repeatedly, particularly around private trust companies and private lending.

September 2025 update

On 3 September 2025 the Government of Jersey published an amendment to the Proceeds of Crime (Low Risk Financial Services Business) (Jersey) Order 2024 (Order), which designated certain domestic lending activity as low risk and exempted local lenders from parts of Jersey’s financial crime framework. 

Following this adjustment, local lenders may now be exempt from Jersey's AML framework if the following criteria can be satisfied:

• the lender is Jersey resident or a Jersey company where each member and director is a Jersey resident;
  
  
• the lender is only registered with the JFSC for the activity of lending (i.e. no other Schedule 2 activity or operation);
  
  
• the lender does not publicly advertise lending services;
  
  
• the lender lends its own funds;
  
  
• all funds related to the lending are paid to and from banks registered with the JFSC; and
  
  
• lending is only made available to Jersey residents or Jersey companies where each member is a Jersey resident.

This is, in our view, a sensible update to ensure proportionality to Jersey's AML legal and regulatory framework. This adjustment to the scope of Schedule 2 is also in addition to updates made in September 2024, designating other activities as low risk, such as certain director services. 

Schedule 2 drop-in sessions 

The JFSC is hosting Schedule 2 drop-in sessions during September and October, as part of its Schedule 2 refresh project. Industry stakeholders are invited to attend drop-in sessions to share their experiences and feedback. The JFSC is currently undertaking a review of its Guidelines on the Interpretation of Article 36 of the Proceeds of Crime (Jersey) Law 1999 to ensure the guidelines are clear, practical, and aligned with both industry needs and Jersey’s international obligations. Revised guidelines are expected to be formally consulted upon later this year.

Next steps 

In terms of further changes to the scope of Schedule 2, we understand that Government is working through an assessment of risk as to other suggested changes and action will be subject to the outcome of that assessment. The Jersey financial services industry will be eagerly awaiting further updates in this space, expected to be delivered at the Government of Jersey's event on 24 November 2025.

Do get in touch with our Regulatory & Risk Advisory team if you wish to discuss changes to Schedule 2 and the Jersey AML framework, as it evolves.