Jamie Bookless
Group Partner*
Guernsey
Guernsey
Guernsey Financial Services Commission (GFSC)
The GFSC has launched its new online Applications and Authorisation Portal which can be found here: Online Services page. The new portal is a central hub that streamlines the applications and authorisations processes. Firms can view their applications (both created and submitted) and communications regarding the submission from the GFSC, as well as download their application decision letters. The previous Word document forms are being phased out and updated into electronic versions that include any supporting documents and can be submitted to the GFSC directly to through the portal.
On 19 May 2025, the GFSC announced the launch of a simplified Private Investment Fund (PIF) regime, which created a highly flexible, innovative and marketable fund structure for a broad spectrum of private capital investments strategies. The full announcement is here and Walkers' briefing on this can be found here.
On 9 June 2025, the GFSC clarified its approach to crypto currency funds (here). The GFSC confirmed that it was open to innovation and is committed to "creating an enabling environment where good business can grow". The GFSC is in discussions with industry about certain aspects of virtual asset regulation.
The GFSC announced the updated Prospectus Rules on 10 June 2025. The updated rules can be found here.
On 12 June 2025, the GFSC announced that it had granted a banking licence to Aston (Guernsey) Limited, which will be known as Bank Aston. Walkers' press release on our involvement can be found here.
On 4 July the GFSC updated the country list in Appendix I of the Handbook on Countering Financial Crime (AML/CFT/CPF), which lists countries and territories that are identified by relevant external sources as presenting a higher risk of ML, TF and/or PF. The British Virgin Islands have been added to Appendix I Croatia has been removed.
On 23 July 2025, the GFSC issued a public statement regarding ITI Trade Ltd. (in Administration Management) and Mr Alex Phil, which can be found here.
On 14 August 2025 the GFSC signed a Memorandum of Understanding with the Capital Markets Authority of Kuwait which provides a framework for cooperation and information sharing between the two authorities.
On 15 August 2025 the GFSC issued some welcome clarification relating to whether a company has an "established place of business" in Guernsey (here). In principle, where a Guernsey person acts a director of a company and they receive a fee for doing so, then they are conducting a regulated activity in Guernsey and, subject to various exemptions, such a person may require a licence from the GFSC or be required to register with the GFSC. One of the applicable exemptions to the licensing/registration requirements is where the person acts as a director of a company with an established place of business in Guernsey. This recent clarification provides more detail as to that concept.
Office of the Data Protection Authority (ODPA)
On 6 May 2025, the ODPA published an article exploring how good data governance not only supports compliance and operational efficiency but also contributes to environmental and business sustainability, highlighting the carbon footprint of email use, the value of data as a renewable resource when managed well (here).On 8 May 2025, the ODPA issued a reprimand against the Committee for Health and Social Care for breaching the Data Protection Law. The public statement is here.
The States of Guernsey (SOG)
On 9 April 2025, a new Chair was appointed to lead new Innovate Guernsey Board, and on 30 April 2025 a further six board members were appointed (the press releases are here and here). The Innovate Guernsey Board was established to support the delivery of the island's digital economy vision and to implement a Guernsey Innovation Plan under the wider Digital Framework. This is a significant development for Guernsey and indicates a move forward with embracing the rapidly growing digital economy.On 3 June 2025, the SOG published guidance following a recent change to UK sanctions legislation. The change in legislation affects dealers in high value goods and art market participants in certain specified circumstances. The guidance document can be found here.
On 10 June 2025, the SOG announced that a dedicated Guernsey Cyber Security Centre is being established to improve the Bailiwick's resilience to cyber attacks (here).
Guernsey Competition & Regulatory Authority (GCRA)
GCRA's Spectrum Licensing Framework document for the deployment of 5G and successive technologies was approved in August 2025, having been published for consultation on 18 July 2025 (here). GCRA is now in the process of accepting formal applications for licences.Jersey
Jersey Financial Services Commission (JFSC)
On 2 May 2025, the JFSC consulted upon disclosable beneficial ownership information with a view to broadening the data to be collected in line with international standards (here). The consultation has looked at whether the current categories and descriptions of beneficial owner and controller are sufficiently broad to capture all types of beneficial ownership and control. It is proposed that additional information in connection with the nature and extent of beneficial ownership is collected, in line with the periodic and ongoing requirements under the Financial Services (Disclosure and Provision of Information) Law. These amendments are considered necessary to ensure Jersey continues to meet international standards, and follows best practices seen in other international finance centre registries.
In terms of timings of these proposed changes, feedback is currently being considered although published feedback has been delayed until Q3 2025. Changes are expected to be introduced from 1 January 2026, so industry will have a 6-month period to update systems and controls to ensure adequate data collection.
On 21 July 2025, the JFSC launched a new Central Authorisations page on its website, bringing together everything related to authorisations in one place. The webpage (here) includes information about the Central Authorisations Unit, general guidance, and sector-specific information.
On 23 July 2025 the JFSC shared a draft version of the revised Sound Business Practice Policy. The proposed revisions have been jointly drafted by the Government of Jersey and the Jersey Financial Services Commission, informed by feedback received from industry stakeholders through the Government of Jersey’s Competitiveness Programme (here).
Of particular interest to local banks, on 24 July 2025 the JFSC published (here) "Bitesize feedback for the banking sector on fraud controls and response". This follows the JFSC's assessment of businesses in this area in Q1 of 2024 and provides concise observations on one page.
The new Jersey Private Fund Guide came into force on 6 August 2025. This further enhances the JPF regime and Walkers' briefing on this can be found here.
Jersey Office of the Information Commissioner (JOIC)
On 7 July 2025, the JOIC confirmed that it will be commencing formal legal proceedings against a number of data controllers for non-compliance with their legal obligation to register and pay the annual data protection fee, as required under the Data Protection Authority (Jersey) Law 2018 and the Data Protection (Registration and Charges) (Jersey) Regulations 2018 (here). This is a reminder to all businesses controlling personal data to ensure compliance by way of payment of the mandatory fee.The Government of Jersey (GoJ)
On 23 May 2025, the Draft Financial Services (Jersey) Amendment Law 202- was lodged for debate. This is the legislation that will make changes to the Financial Services (Jersey) Law 1998 that will introduce a statutory consumer credit regime into Jersey law. The draft legislation was unanimously voted through on 9 July 2025 and is expected to come into force on 1 January 2026. You can read more about the expected changes in our briefing (here).
On 11 July 2025, the GoJ launched (here) proposals to repeal the control of borrowing framework. This would entail replacing the Control of Borrowing (Jersey) Law 1947 and the Control of Borrowing (Jersey) Order 1958 with a modern, proportionate, and internationally aligned gatekeeping framework. The consultation closes on 30th September 2025.
Similar to Guernsey, cyber security is in focus in Jersey. On 22 July 2025, the GoJ launched a consultation on the draft Cyber Security Policy Framework, which builds upon the work of Jersey's first Cyber Security Strategy, which raised awareness of the Island's vulnerabilities and the need for collective action (here). The Jersey Cyber Security Centre is now operational and the Cyber Security (Jersey) Law 2025 will formalise its role in co-ordinating cybersecurity intelligence and promoting good cybersecurity practice for the Island, while placing duties on Operators of Essential Services to improve the Island's cyber resilience.
Jersey Competition & Regulatory Authority (JCRA)
On 22 July 2025, the JCRA issued an update (here) confirming it is launching a new advocacy-first approach to upholding Jersey’s competition law. The focus will be on increasing awareness of the competition law and policy issues through improved engagement with businesses and consumers. The aim is for Jersey’s markets to become more competitive, for the benefit of all.About our Channel Islands Regulatory & Risk Advisory team
Our Channel Islands' Regulatory & Risk Advisory team has a dedicated team of regulatory experts spanning all practice areas who regularly advise on all aspects of Guernsey and Jersey regulation and tax, including financial services, AML, sanctions, data protection, consumer protection, competition, tax (including Pillar Two), economic substance, FATCA and the CRS. Our team can also provide training to staff on a broad range of topics.
