Thank you to everyone who attended our prescribed NPO Town Hall event on 23 October, we hope that the event was insightful. 

If you’d like to give us any feedback on the event, please complete our survey.

Watch our event highlights:

If you could not attend the event, we have summarised the key topics and questions discussed below for your convenience.

Overview of the NPO framework

We kicked off by explaining when an NPO needs to register:

Step 1: does your NPO need to register with us?

If your NPO is solely or primarily raising or disbursing funds for non-profit purposes such as:

• charitable
• religious
• cultural
• social
• fraternal
• other types of good works

you are required to register with us.

Step 2: is your NPO considered a Prescribed NPO?

An NPO will be considered Prescribed if it meets the following definition:

Any NPO that, during the preceding 12 months has, raised, or disbursed more than £1,000 from outside Jersey, Guernsey, the Isle of Man, England, Wales, or Scotland over the past 12 months.

We then explained the additional obligations for Prescribed NPOs:

The additional obligations are listed under the Non-Profit Organisations (Prescribed NPOs – Additional Obligations) (Jersey) Order 2022 and additional guidance can be found in Section 17 of the JFSC’s AML/CFT Handbook.

Just because a NPO is Prescribed does not mean the entity is considered high risk or there is reason for concern. The legislative framework seeks to protect the sector from misuse for terrorist financing and the obligations within the Order formalise measures that may already be in place.

Question: when should you tell us that you believe your NPO has become Prescribed?

If you believe your NPO may become prescribed, such as prior to disbursing funds to a country not listed above, then contact our NPO team to let us know. We can provide additional help and guidance to make sure you meet your obligations.

An NPO is considered Prescribed as soon as it meets the definition set out in “step 2” above. We encourage you to plan in advance so that you are meeting the additional obligations. As a reminder, any changes must be sent to us in writing within three months.

Our team are happy to provide you with an overview of the prescribed obligations before this happens – please get in touch.

Thematic examination 2024: what were the key findings?

Earlier this year, we conducted six thematic assessment visits to look at what controls NPOs had in place to help mitigate diversion risk.

The visit identified elements of good practice and areas for improvement:

Good practices observed

• using a combination of methods to mitigate diversion risk such as on-the-ground visits, in-person meetings and/or video conferencing, receipts from spending, progress reports, photographs – in general avoiding over-reliance on any one method.

Areas for improvement:

• insufficient information obtained on where and how Associate NPO’s and Beneficiaries’ funds were being used after receipt
• understanding by the Boards/Governors of what diversion is and how it may manifest itself in their organisation
• reliance on anecdotal confirmations or limited evidence on how funds were being used.

Introduction to the Financial Sanctions Implementation Unit (FSIU)

Dan Marcos, Head of International Compliance, at the Financial Sanctions Implementation Unit (FSIU) attended our event to give an overview of the FSIU’s role.

The FSIU coordinates the introduction of sanctions measures and sits within the Ministry of External Relations to support the Minister in his role as the Competent Authority.

Although not a mandatory requirement, a prescribed NPO may wish to screen any person who has significant influence over the NPO activities against the relevant sanctions lists to act as a control against terrorist financing risks.

Further information regarding screening can be found in Section 17.5.3 of our AML/CFT/CPF Handbook.

Mitigating diversion risks

We then discussed the topic of “diversion” — this can be described as funds being diverted away from the intended recipient to a terrorist, terrorist cell or terrorist organisation to directly or indirectly benefit them.

To mitigate these risks, NPOs should:

• identify Associate NPOs/Beneficiaries you work with
• obtain reasonable assurance that the NPO’s funds have reached their intended destination in full for its’ intended purpose.

Implementing this risk-based approach can protect both the NPO and our island’s NPO sector from reputational damage, while also enhancing donor confidence.

MONEYVAL overview for NPOs

We provided an overview of the importance of Jersey’s compliance with international standards following Jersey’s recent MONEYVAL assessment.

NPOs were reminded of their role in maintaining strong governance to protect both their organisation and the Jersey’s reputation.

New data collection survey

Thank you to al NPOs who completed our data collection survey last year. Your responses ensure that our record of your NPO remains accurate and up to date.

We have now sent prescribed NPOs a new data collection request for 2024 via email.

Please use the link in the email and answer the questions through our online survey by 11:59pm on 11 April 2025.

The data we collect is an important part of what we do as it ensures we have a good understanding of the NPO sector, to ensure we continue our risk-based approach to supervision.

Notify us of changes

Let us know if any minor or material information relating to your NPO has changed since you registered with us, as per Article 9 of the Non-Profit Organizations (Jersey) Law 2008 and Article 1 of the Non-Profit Organisations (Order) 2022.

This could include changes to your NPOs registered status, or if your NPO meets the definition of being a Prescribed NPO.

Notify us of changes within three months of the change, in writing to npoenquiries@jerseyfsc.org.

• NPO drop-in sessions in 2025
• continued collaboration with the Jersey Charities Commissioner.

See our upcoming events and webinars

Is there a topic you'd like us to cover in our next newsletter? Get in touch and let us know

Visit the NPO section of our website for additional information and video guidance. 

• you can access our PowerPoint presentation from the event on our website: NPO annual update 2024 — Jersey Financial Services Commission
• Non-Profit Organizations (Jersey) Law 2008 (jerseylaw.je)
• Non-Profit Organisations (Prescribed NPOs – Additional Obligations) (Jersey) Order 2022 (jerseylaw.je)
• is-your-organisation-an-npo-and-what-that-means-in-practice.pdf (jerseyfsc.org)
• handbook-section-17.pdf (jerseyfsc.org) – Section 17
• https://www.jerseyfsc.org/industry/sectors/non-profit-organisations/