JFSC publishes AI guidance for Jersey’s financial services sector

The Jersey Financial Services Commission (the JFSC) has published its awaited guidance on the use of artificial intelligence (AI) in Jersey’s financial services sector, providing a clear indication of JFSC’s expectations as firms integrate AI into their business operations.

The new guidance does not introduce a new AI-specific regulatory regime, instead it confirms that the JFSC expects firms to apply their existing regulatory obligations to the use of AI, adopting a proportionate, risk-based approach that reflects the nature, scale and complexity of their business.

The guidance note is available here: JFSC Guidance Note on the Use of AI in the Financial Services Sector

For firms already using, or considering the deployment of, AI tools across areas such as client onboarding, compliance, investment management, fraud detection, customer communications or operational processes, the message is clear: responsibility cannot be delegated to technology. Boards and senior management remain ultimately accountable for decisions made with the assistance of AI and for ensuring that appropriate governance and oversight arrangements are in place.

The guidance encourages firms to consider a number of key areas, including:

• governance and accountability for AI systems;
• risk identification and management, including accuracy, bias and explainability;
• appropriate human oversight of AI-assisted decision-making;
• robust data governance, cybersecurity and operational resilience; and
• ongoing monitoring, testing and review of AI systems throughout their lifecycle.

From a governance perspective, firms should also consider whether their existing policies and procedures adequately address AI use. This may include reviewing outsourcing arrangements with third-party AI providers, contractual protections relating to data use and confidentiality, internal AI governance policies, record-keeping practices and escalation procedures where AI-generated outputs influence regulated activities or customer outcomes.

The guidance also sits alongside firms’ wider obligations under Jersey’s data protection, anti-money laundering and corporate governance frameworks. The introduction of AI into regulated processes does not diminish these obligations; rather, it reinforces the need for firms to understand how AI systems operate, the risks they present and the controls required to manage those risks effectively.

The publication reflects the JFSC’s continued support for responsible innovation and aligns Jersey with the broader international trend towards principles-based AI regulation. Rather than discouraging adoption, the guidance is intended to enable firms to innovate with confidence while maintaining appropriate governance, transparency and accountability.

For Jersey financial services businesses, now is an appropriate time to assess existing and planned AI use cases, evaluate governance frameworks and ensure that boards are equipped to oversee AI-related risks as part of their broader enterprise risk management responsibilities. Early engagement with legal, compliance and risk advisers will help firms demonstrate that AI adoption is both commercially effective and regulatorily robust.

For additional information or for any questions, please reach out to your usual Mourant contact or one of the key contacts on this page.