Update

Jersey's proposed Mandatory Disclosure Rules

Mandatory Disclosure Rules are now expected to be in place in Jersey by the end of the year, changing reporting obligations for intermediaries who are promoters or service providers for Reportable Arrangements that meet the trigger threshold.

Although there are still several months to prepare, there are practical steps that could usefully be taken now. This includes undertaking some internal due diligence, developing training and policies and procedures to identify Reportable Arrangements, checking client terms and conditions and/or privacy statements and developing new procedures for collecting required information and reporting to the Comptroller.

This Update sets out the scope of the new Regulations that are being adopted in response to Jersey's commitment to the EU Code of Conduct Group to introduce a mandatory disclosure regime and provides some practical guidance on next steps for affected intermediaries.