Jersey Financial Services Commission Annual Report 2024

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Highlights at a glance Facilitate business integrity

1,926 Registry  

inspections

1,373

pieces of information  received by Intelligence  

18 sanctions  

issued

130

external policy  queries managed

54 whistleblowing  

calls received

108

external shares  of intelligence to  14 different jurisdictions

Key Persons  consultation launched following industry

feedback

520

intelligence reports

disseminated  New

guidance 66  issued

for Jersey  iSARs  Private Funds

externalised

Highlights at a glance  

Harness technology Develop our people,  

systems and capabilities  

5 Registry  8%

new online forms   system core   of colleagues  on myJFSC portal upgrade  are returners

completed

to enable future user

ISO 27001  experience  £341,000

improvements

and Cyber  spent on learning  Essentials  and development

certifications   13 publications

achieved  from our Innovation  

Hub, including  

on RegTech  

and tokenisation

        Jane Platt CBE

Chair

Jersey Financial  

Services Commission

Since joining the organisation in April 2024, I have      

bfaeceiln itsattrinug bck buy tsinhee Jss tFShaC tt seaafmeg's cua ordms Jmeitr mse ey n' t ts bo est       economic interests, while protecting consumers      

and preventing financial crime.      Alongside the significant successes of this        

yMeOa Nr, nEYot lVAe La s mt t uh tue s alt ero vn alg ouatu iotc no , m 20e o 24f J ae lsr os ey's          presented our organisation with significant          

cinhcarleleansegdess, icnructliundyi.nWg tewreo dcoagtna biser ethaechimes apanctd      

of these incidents on our stakeholders and have    

taken lessons forward from them, as we share

in this report.

Against this backdrop, with both onshore jurisdictions and international finance centres seeking to offer quality services at reasonable prices, Jersey's competitiveness on the international stage is a key focus. Supporting Jersey's long-term economic success is one of our guiding principles. In 2024 we laid the groundwork for several initiatives focussed on competitiveness, including an independent review into our fee model.

In increasingly difficult global conditions, Jersey's stability and strong international reputation

as a well-regulated jurisdiction are important assets to leverage.

6

Our commitment to stakeholders The year ahead

Strong stakeholder relationships are central to regulatory  The Government of Jersey's financial services effectiveness. We must continue to meet international regulatory  competitiveness programme provides us with an standards to ensure effectiveness in fighting financial crime and to  opportunity to simplify legislation, increase the enable Jersey's long-term success and market access. This year we  ease of doing business in Jersey and strengthen continued to foster global relationships, including with international  cross-agency collaboration. We will also

regulatory bodies and peer regulators, to share best practice, support  complete the current stage of our strategy and cross-border supervision and explore new opportunities.  lay the groundwork for the next. Supporting the

competitiveness agenda, underpinned by a shared We work closely with the Government of Jersey to ensure effective  understanding of risk, will be a key focus for the year. implementation of legislation passed by the States of Jersey Assembly.

We also seek feedback from industry through regular meetings with

industry bodies and our annual survey. This engagement has helped

to shape the work we have done in 2024 and our plans for next year.

7

Jill Britton

Director General  Jersey Financial  Services Commission

2024 overview We are also committed to addressing the significant

challenges that 2024 presented, including two data On 24 July 2024, MONEYVAL, the Council of Europe's permanent  breaches and increased scrutiny, in an open and

monitoring body, published their Mutual Evaluation Report for Jersey.  solution-focussed way. We have strengthened our The report confirmed that Jersey's effectiveness in preventing financial  cyber security, achieving Cyber Essentials and ISO crime is among the highest levels found in jurisdictions evaluated  27001 certification, and continued to increase our around the world. engagement with industry and other stakeholders

to enable continuous feedback.

This positive outcome from the evaluation is critical to Jersey's

long-term economic success. This was a significant part of our story  We recognise the importance of balancing effective this year, and an achievement that many JFSC colleagues contributed  regulation with an enabling regulatory environment to and are proud of. for reputable business. We have listened and learned

on where we need to do better, including improving our service levels.

In 2024 we continued to move through the necessary business transformation to make these improvements and remain committed to this process of renewal

in 2025.

9

         Local context

Jersey continued to face challenges related to

        inflation and cost of living in 2024, which has

      affected all islanders, including the local business community. As the financial services regulator, we

      are very much alive to the island's growth agenda.

        Our focus in 2025 will be to define and advance delivery of the JFSC's part in that agenda, working

         alongside the Government of Jersey and industry.

10

2024 operational developments      

This year we developed our "operational excellence" framework,     dvaelluiveefreord mthornoeuyg,hs eforvuircefo ecxucse allreenacse: raengdu leamtoprlyoyeeffee ecxtipveenrieesnsc,e  .      

Stakeholder feedback has fundamentally shaped the model    

and helped us prioritise which improvements to address first.     Alongside the sustained improvement in service delivery      

itno ofeuer sRceognissturylt adt ii vo isn is o, n a , l wig en i an lg s  oo ular u f ne ce h c ey dc ale n wei wth a t ph pe r boau cd hg et  

cycle to provide a clearer link for industry between what

we charge and what we spend.

The year ahead

As we move into the new year, we will take the lessons of 2024 forward without losing momentum on our important strategic  commitments. We have an ambitious programme of work ahead including:

developing a new strategy, prioritising stakeholder input and  stability for industry

completing JFSC-specific Recommended Actions from Jersey's  MONEYVAL mutual evaluation  

conducting a strategic review of our Registry to support Jersey's  standing as a jurisdiction of choice

continuing to deliver digital improvements for industry, including:

- more enhancements to our portals

- improving our website's search functionality and user experience

- developing and enhancing how we collect data to reduce the burden on industry and ensure we are using our resources effectively as part of our risk-based approach

finalising the framework for consumer credit so that Jersey consumers can benefit from consistently high standards of transparency and best practice

supporting the Government of Jersey's delivery of its sustainable finance roadmap

increasing international engagement, alongside the Government of Jersey and Jersey Finance, to support the economic growth agenda

developing the capability to add intellectual property and trademark registers to the services provided by our Registry

- working with industry to operationalise our new platform providing obliged entities access to beneficial ownership information, exploring further development of this platform alongside government to provide access to those with legitimate interest

starting the revision of the structure and competitiveness of our fees following KPMG's independent review in 2024

supporting the Government of Jersey's financial services competitiveness programme

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Who we are  Our mission

We are the regulator for financial services in Jersey, responsible for  Our mission is to maintain Jersey's position as regulating, developing and supervising the island's financial services  a leading international finance centre, with high industry. We also supervise non-profit organisations, virtual asset  regulatory standards, and to adhere to our guiding service providers and designated non-financial businesses and  principles, which are set out in law, to:

professions for anti-money laundering, countering the financing

reduce risk to the public of financial loss due

of terrorism and countering proliferation financing purposes.

to dishonesty, incompetence, malpractice, or the

financial unsoundness of financial service providers We aim to deliver balanced, progressive, risk-based financial

regulation, built on insight, integrity and expertise. We also operate  protect and enhance the reputation and integrity the Companies Registry, which registers Jersey companies,  of Jersey in commercial and financial matters partnerships, foundations and business names. safeguard the best economic interests of Jersey

counter financial crime both in Jersey and elsewhere

15

What we do  

Our statutory responsibilities are set out in legislation and include: We aim to fulfil these responsibilities by:

authorising, supervising, and developing financial services in or from within Jersey

discharging our functions as set out in the Commission Law and other legislation

reporting, advising, assisting, and informing the Government of Jersey and other public bodies in relation to financial services matters

preparing and recommending to the Minister amendments to financial services legislation

operating the Companies Registry

ensuring that all authorised financial services businesses and individuals meet the appropriate criteria and that we, as the regulator, meet appropriate international standards relevant to the sectors we supervise

playing our role in combatting financial crime as part of the wider international effort

working closely with fellow regulators and lawmakers to ensure access to efficient and effective markets for financial services

reacting to and, where appropriate, anticipating changes in markets and the financial services industry by developing policy and the way we supervise

acting as an agile, thoughtful, proportionate regulator that gives fair consideration to both the costs and benefits of regulation

supporting the Government of Jersey in its strategic objectives as set out in the Common Strategic Policy

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Our external-facing teams

Supervision Policy

The Supervision division maintains the JFSC's relationship with  Our Policy team maintains the regulatory framework keeping regulated businesses, assessing the way in which they maintain  legislation and codes up to global standards, working with sustainable business models, treat customers, or develop  international policy makers and governments.

appropriate controls to mitigate the risks of financial crime.

Supervision does this through engagement with firms and  Innovation

taking a risk-based approach to supervision and examinations. The Innovation Hub supports the development and adoption of new

and innovative technology in financial services. The hub provides Registry a dedicated point of contact for firms to raise enquiries with

The Registry's primary function is to consider and assess  competent authorities on Fintech and RegTech related issues and incorporation applications to ensure they comply with legal  seek non-binding guidance on regulatory expectations.

obligations and the island's risk appetite.

Our Registry maintains 15 registers including Jersey companies, business names, foundations, partnerships and security interests.

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Enforcement

Our Enforcement team investigates and, where appropriate, takes or proposes action against businesses and individuals which do not comply with our regulatory and legal requirements, investigating actual and potential cases of serious regulatory misconduct.

Intelligence

Our Intelligence division works closely with Enforcement, Supervision and Registry, developing intelligence to enhance our activities as a risk-based regulator. The Intelligence division is also responsible for maintaining the JFSC's whistleblowing line and works closely with law enforcement agencies and the Financial Intelligence Unit, Jersey.

Financial Crime Coordination

Our Financial Crime Coordination team supports the embedding and ongoing improvement of our processes for the prevention and detection of financial crime, ensuring ongoing effectiveness in meeting international standards. The team is also responsible for the delivery of the MONEYVAL Recommended Actions Plan (published November 2024).

Risk

Our Risk team support us through the deployment and oversight of a robust enterprise risk management framework and facilitate a deeper understanding of regulatory risk. The Risk team houses the JFSC General Counsel and Data Protection Officer.

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Facilitate business  Harness technology  Develop our people, systems, integrity and influence the digitalisation  and capability to be a high

of financial services performing organisation

19

Alignment with island priorities

Our strategy aligns with the government's Future Jersey vision, including the following Island Outcomes for economic wellbeing:

• business environment – Jersey is an attractive and competitive place to do business
• jobs and productivity growth – Jersey encourages talented people to remain employed here, and attracts others who can help businesses grow, become more productive and help create better employment opportunities for islanders

Our culture and approach

We are a values-driven organisation. We promote a culture of listening and responding to our stakeholders to make sure we are continuously improving. We are focussed on strengthening and embedding this approach across the JFSC. We are accountable through our governance structures as set out in law and through a programme of continuous engagement with our stakeholders.

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Facilitate business integrity

Facilitating business integrity involves supporting businesses to:

reach greater maturity in risk management

improve their understanding of regulatory standards

adopt an active approach to compliance

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Conduct and prudential

We continued work to align our policy framework to prevailing Basel standards to support cross-border  banking businesses. This included consulting on and agreeing our proposed roadmap for implementing the final set of Basel III reforms.

As the first step in the roadmap and following consultation with industry, we have implemented some quick wins by updating relevant guidance notes and Codes of Practice, which came into force on 1 January 2025.

We supported the Government of Jersey to draft a new consumer credit law and drafted a Code

of Practice for the new regime. Another key focus was supporting government with the development of Jersey's Sustainable Finance Action Plan, laying the groundwork for important developments

in this space in 2025.

We have started the rebalancing of our supervisory approach on conduct and prudential matters, alongside our ongoing financial crime focus, through the creation of a new prudential team to focus on firms which exhibit risks to their financial viability. We have started work to examine conduct risks in firms, including banking fraud.

We also continued our work alongside other agencies and the Fraud Prevention Forum to raise awareness among islanders and share best practice in fraud prevention.

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Authorisations statistics Schedule 2 registrations

Licence type 2022 2023 2024 Alternative investment fund services business 6 11 16 Auditors 7 4 6 Banks 1 0 1 Collective investment funds 26 35 39 Control of Borrowing Order (CoBO) 157 126 153 Fund services business 28 17 25 General insurance mediation business 3 7 4 Investment business 2 3 4 Insurance 7 5 4 Jersey private funds 195 136 115 Money services business 1 0 1 Non-profit organisations 29 117 44 Trust company business 21 25 22 Total authorisations 483 486 434 Total cessations and revocations 256 452 409

Licence type 2022 2023 2024

Schedule 2 business (Direct) 27 241 243 Schedule 2 business (AMLSP) n/a 2,691 1,476 Total Schedule 2 registrations 27 2,932 1,719 Total Schedule 2 revocations 25 48 8241

1The increase in revocations is due to changes to the anti-money laundering service provider regime, with entities/arrangements subsequently falling out of Schedule 2 registration.

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Registry developments

Our Registry is important for a broad range of stakeholders, including local businesses  alongside international financial services companies. Key developments this year included:  

completing our visit assessment programme in conjunction with Supervision where  

the trust company service provider agreed to this approach, to support the authentication and verification of information on the register. This included 888 regulated entity visits and 1,038 local business visits

completing the first full year of overnight screening, for all significant persons documented

within the core Registry and JFSC systems to check for adverse media related to financial crime and financial sanctions. The screening is designed to identify any changes in risk from parties who could harm the island. No new information was discovered in this screening, underscoring the effectiveness of the risk assessments we have performed

laying the groundwork for the 2025 strategic review of our Registry, to support the  

long-term needs of our stakeholders, including considering the range of products available, streamlining people s interactions with us and supporting ease of access to our services. This includes consideration of international standards and best practice

  continuing to build knowledge and experience in the Registry team with the roll-out

of updated policies and procedures to support the consistency and quality of the service we provide to Registry users

completing the core upgrade to the Registry back-office system, as shared in the

technology and data section below

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Registry statistics

2024 2023 Live entities* 38,820 38,544 Total registrations* 2,859 2,759 Company incorporations 2,501 2,464 Company dissolutions 2,434 2,452 Companies migrated in (continuance in) 129 184 Partnership dissolutions cancellations 148 236

*The live entities and total registrations include all legal entity types.

32

Innovation Hub

Our Innovation Hub continued their work to support and enable innovation in financial  services by embracing digital technology. This included launching our AI-powered  regulatory chatbot "Reggie", to provide a self-help platform for regulatory questions,  increasing ease of access, navigation and understanding of Jersey's regulatory  framework. Initially launched in beta, Reggie currently uses our Codes of Practice  and the Anti-Money Laundering and Countering Terrorist Financing Handbook as its  knowledge base, with more resources to be added over time.

Alongside new asset tokenisation guidance, we have also provided guidance to support  industry in accessing the benefits of regulatory technology (RegTech), including  increased team capacity and high standards in regulatory compliance.  

We recognise that our people and systems are critical for delivering regulatory effectiveness. Key developments in building our organisational  capacity and capability in 2024 included:

establishing an Operational Excellence team to embed  continuous improvement into how we operate as an organisation.  The team's work this year included input on our fees reform to  ensure fee accuracy and improve billing and management  

of fee queries  

continued focus on retaining colleagues and improving their  knowledge and experience. While employee turnover saw a slight  increase in 2024 compared with 2023, at 19% for the trailing 12  months to December 2024, it remains well below the highs seen in  2021, giving us an average length of service of 4.5 years. Our work  in this area included:

increasing the capability of our workforce through a sustained focus on learning and development

reviewing our technology landscape to identify areas of duplication, waste and unnecessary complexity so we can "do more with less"

engaging a user experience expert in Registry, to identify how  we can better support service users, including improvements to

our online content and guidance. The output of their work is helping us design better customer journeys and remove process steps,

so colleagues and end users have improved ease of use and simplified functionality

- continuing to actively welcome returners to the workforce as part

of our recruitment efforts, with 8% of colleagues being returners,  internal service desk capabilities transferred to a third-party, rising to 13% in our Supervision and Enforcement teams freeing up our Technology and Data team's capacity for strategic

delivery and other digital improvements for industry

- launching targeted training for our people managers and an in-role

career pathways framework to support career progression  Continued enhancements made to our risk and control

framework - see the risk, legal and data protection

- a positive trend of supporting internal mobility, with internal  section for further details

promotions running at 13% of all appointments in 2024, ensuring

industry can benefit from working with experienced employees

- enhancing our approach to recruitment with candidates scoring 9/10 on recruitment experience and almost 30% of new hires coming through internal referrals, which leads to better outcomes

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1Last year the 2024 results were presented under the 2023 data, as the survey began in Q4 2023 and completed Q1 2024. We are now aligning

the surveys with the year in which they completed. 44

45

46

KPI: Staff engagement

Annual staff happiness index survey

47

KPI: Staff retention

Increase in staff retention

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As an organisation that works with numerous jurisdictions and organisations across the globe, we have drawn from the United Nations Sustainable Development Goals (SDGs) to add structure and rigour to our internal ESG goals.

As this is a global framework, it is more likely to be recognisable to our international stakeholder community, supporting accountability among our various stakeholder groups.

50

Gender pay gap

We are voluntarily publishing our gender pay gap as part of our ongoing commitment to inclusion and greater transparency.

Definition of the gender pay gap

The gender pay gap is the difference between the average hourly pay for men and women across an organisation. This figure is expressed as a percentage of men's earnings. A positive percentage figure shows that women have a lower average hourly pay than men, whereas a negative percentage shows that men have

lower average hourly pay than women. In effect, the gender pay calculation functions as a high-level overview of an organisation's gender pay balance.

What the gender pay gap is not

The gender pay gap is not a reflection on pay equity, which refers to men and women receiving equal pay for doing the same or similar jobs. All JFSC colleagues are remunerated on externally benchmarked pay scales with equivalent pay for comparable positions, therefore ensuring pay equity.

Median vs mean

The median pay gap is calculated by finding the exact middle point between the lowest and highest paid male colleagues in the JFSC and the lowest and highest paid female colleagues. We then compare the two figures. The mean pay gap is calculated by adding up the hourly pay of all the female colleagues in the JFSC and dividing that by the total number of females. We then do the same sum for male colleagues and compare the two figures.

52

Gender pay gap report

Below is our gender pay gap data for 2024 as at 31 December 20241:

Female employees 130

The 10.7% mean gender pay gap shows that, overall, women's average (or mean) hourly salary is lower than men's average salary. In many organisations a gender pay gap indicates a lack

of women in senior positions, however this is

not the case at the JFSC. At all levels other than grade 8, there's either gender balance or a greater proportion of female colleagues. Our Executive team has a 57% to 43% female-to-male ratio, and our Commissioners have a 75% to 25% female-to- male ratio.

Male employees who received a bonus2 85%

1All gender pay calculations are based on both temporary

and permanent colleagues, while contractors, agency employees and secondees have been excluded.

2Employees must have passed probation and attain a performance rating of 3/5 or higher to be eligible for a bonus.

53

The core disparity is in our junior grades 2-4, where  there is a significantly greater proportion of women  to men which impacts both median and mean gender pay gaps. Our response to the gender pay gap at the JFSC will therefore need to focus more on this gender disparity at junior levels. We will take time to consider this further.

In support of our people strategy vision to be a leading employer in Jersey, we have an aspiration to develop an inclusive culture with a diverse workforce. We include awareness of bias and discrimination within our manager training to drive appropriate decisions around hiring, promotions and allocation of development opportunities.

We also have an in-role promotion pathways framework to support career movement in our junior grades.

Grade 1 is the lowest salary band, and 9 is the highest.

54

In 2024 we began to embed our operational  All four areas contribute to developing Jersey's  excellence balanced scorecard to drive  caonmd peneatibtilvinegnegsrsoawst ha nb yinatettrrnaacttioinnga lafindn arnectaei ncienngt re  

improvement in our operational performance. quality business.

We target operational excellence through  Progress in 2024 included:

four focus areas: 1to6 7a chto fuorrs psrainvecidp ablyaanudt okmeya tpinegrs tohnes cperaosciensgs

regulatory effectiveness 281 hours saved by launching the change to

anti-money laundering service provider (AMLSP) value for money legal person application form and AMLSP legal

arrangement application form

service excellence  380 hours saved by launching the AMLSP

employee experience  Schedule 2 revocation form

68% of incorporations completed within the requested timeframe, a 24% improvement

from 2023

82% of maintenance submissions completed within two days, a 49% improvement from 2023

84% of phone calls answered in our Registry, a 21% improvement from 2023

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During 2025 we will begin reporting on our Operational Excellence framework with a selection of measures that matter for our stakeholders. These measures will include performance against service level agreements in Registry, Supervision and Authorisations, along with some other relevant indicators of progress.

We will develop this measurement and increase transparency to show progress and build external understanding. Alongside this, relevant teams will engage directly with industry to deep dive

on topics, such as our approach to authorisations and data collection.

57

We conduct engagement through many different channels,  

including in-person meetings, roundtable discussions and conference  attendance with industry bodies, our annual industry survey  

and our consultations.  

Our outreach, both nationally and internationally, is an important part  of our role, particularly in supporting Jersey's competitive positioning  as an international finance centre.

We interact with more than 30 stakeholders locally and in 2024  participated in 126 engagements on the island. Internationally  

we are a member of five international organisations and conducted  30 international engagements across the year.  

59

We supported international  efforts in combatting financial

crime by delivering the Regional

Financial Crime Programme, in

collaboration with the Toronto

Centre and Jersey Overseas Aid.

This was a five-day event bringing

together financial supervisors

from six jurisdictions to advance

international cooperation and

strengthen regulatory strategies

to combat financial crime.

60

This year we hosted the Italian and Swiss Ambassadors alongside      rperperseesnetendtaatinv eospfproormtutnhiteyir f aocr cooumr pjuarnisydinicgti odnesle tgoa etixocnhsa. nBgoethin vsisigithst s    

and explore areas for future collaboration.    We continued to work closely with local partners such as the      

Ganodv earrnem aecntitv eof mJeermsebye,r Jse irns emyoFrienathnacne 1a4ngdoDviegrintaml eJenrts-leeyd t whiosr ykeinagr,    

and advisory groups.

Industry engagement has remained a focus for us this year,

with both our Director General and Chair meeting with more than 15 senior leaders within industry to discuss key trends and issues.

We have enhanced how we are communicating with industry, with the roll-out of monthly vlogs by Supervision directors, workshops and events tailored to specific stakeholders, including a workshop for regulatory consultants, and significant outreach to designated non-financial business and professions, non-profit organisations and virtual asset service providers.

In 2024, a total of 14 complaints were submitted  to the JFSC, which are shown below by division.

2024 complaints by division  1

Registry  10

Supervision (Authorisations) 2

Enforcement  1 1 People & Culture  1

Of the 14 complaints received in 2024, 10 were upheld.

Wcoemcpalnai nctosnwfiremre t shyastt tehme pmraimlfaurnyc tisiosnuse sa nidde pnrtoificeeds sb- yre tl ha ete d  2 errors, including miscommunications and delays in actioning

queries. To protect confidentiality, we are not able to provide

details about specific complaints.

We have apologised to any individual who raised an upheld

10 complaint and rectified the issue where possible. We also

explained why the error occurred and the steps we have

taken to prevent the issue reoccurring.

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Income Capital expenditure

Total income for 2024 reached £33.6m (2023: £29.7m) following  Capital expenditure for 2024 was £0.2m (2023 £0.2m)  

an increase in regulatory income, primarily related to the increase  and remains negligible due to the anticipated building move, in regulatory perimeter due to designated non-financial businesses  with the focus remaining on systems.

and professions income of £3m (2023: £1.9m) together with

increased revenue from funds of £9.8m (2023: £9m). The net book value of fixed assets has reduced to £4.8m

(2023: £6.4m), with amortisation being the main movement.

Registry income reached £8.3m (2023: £7.2m) primarily

due to the increase in annual confirmation income to £5m  Financial position and look forward (2023: £4m) and the incorporations income to £1.2m (2023: £1m).

Our retained liquid asset position decreased to £7.6m at 31 December Operating costs 2024 (2023: £13.2m) driven by the move to an annual invoicing of

regulatory fees in January. As a result December is the lowest point Total operating costs increased by £2.3m (8%) to £32.4m. in the liquid asset cycle.

Staff costs are the most significant item of expenditure,  The level of retained liquid assets supports the continued representing 70% of our cost base. Staff costs increased by £3.4m  investment in our change programme and planned initiatives driving (17%) compared to 2023, driven by a 7% increase in the number  improvements in our core system and website. This also ensures

of permanent employees. Professional fees decreased by £2.8m,  that, if a significant adverse event occurs, we would retain the driven by the successful MONEYVAL evaluation. Depreciation,  financial ability to continue with business critical projects, in addition amortisation and impairments remain stable year-on-year at  to our normal regulatory and Registry operations, while appropriate £1.6m, with investment in systems being predominantly operational  action is taken.

in nature rather than capital.

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Horizon scanning

As we navigate an increasingly complex and dynamic risk landscape, including geopolitical tensions, macroeconomic uncertainty, rapid evolution of emerging technology, and demographic challenges, we remain committed to proactive and adaptive risk management.

We closely monitor global macroeconomic and geopolitical developments, leveraging information and data at our disposal to inform our responses. By keeping track of emerging technologies and their potential impacts, we continue to assess and adjust our risk appetite to support the ongoing competitiveness of Jersey.

To enhance our effectiveness, we have increased our investment in AI technology to drive innovation and efficiency. Open communication with stakeholders remains a focus, ensuring we enhance transparency and collaboration. We have also refined our people strategy to strengthen our capability and resilience, ensuring that our teams are equipped to meet the evolving challenges and opportunities ahead. This approach has enabled us to maintain a robust and responsive stance in the face of an ever-changing risk environment.

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Enterprise risk management

Through our enterprise risk management framework, we actively identify, measure and manage principal risk exposures facing the JFSC as an organisation. We work collaboratively within our governance structures to assess these risks and implement appropriate and measured responses that protect the JFSC, evolve our risk culture and ultimately support us in delivering on our purpose.

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Some of the principal risk exposure that have been our focus for 2024 include:

Related strategic anchor: Harness technology / Develop our people, systems, and capability

Human or technical weaknesses are exploited, allowing access to critical systems and highly sensitive data.

Mitigation

We align our approach with industry best practice and have attained our ISO27001 certification and Cyber Essentials certifications. This ensures our information security management system and technical controls are robust and effective in guarding against evolving cyber threats.

Risk: Critical system disruption

Related strategic anchor: Harness technology

Disruption to business-critical systems and architecture impacting operational efficiency and regulatory effectiveness.

Mitigation

Through our system and infrastructure design, embedded approach to Business Continuity Management, along with regular testing and simulation activity we ensure disruption to critical business systems is kept to a minimum.

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Related strategic anchor: Develop our people, systems, and capability

Lack of capacity and capability across the JFSC to be able to meet current demands  for business as usual as well as strategic delivery.

Mitigation

We have a defined people strategy underpinned by best practice approaches to recognition, performance management and learning and development. Supporting key measures that matter are monitored and overseen by our Executive and Board.

The work of the JFSC's Innovation Hub continues to identify and deploy new technologies to enable a more efficient and effective workforce.

Risk: Third party

Related strategic anchor: Develop our people, systems, and capability

Inadequate management and oversight of third parties leading to service and quality disruption, as well as reputational risk.

Mitigation

Our response is supported by a newly established third-party risk management approach to ensure risks associated with third parties are identified and managed throughout their lifecycle. This work is overseen by a dedicated procurement function.

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Related strategic anchor: Harness technology / Develop our people, systems, and capability

Failure to execute and continually evolve our data strategy impeding our ability to capitalise on the benefits to both the JFSC and industry.

Mitigation

We have a defined data strategy with Executive ownership, supported by a programme to ensure appropriate data governance, training and upskilling, and tooling. Progress against this strategy is overseen by our Board.

Risk: Insider threat

Related strategic anchor: Develop our people, systems, and capability Confidential and/or sensitive information is misused by those with authorised access.

Mitigation

Access to confidential and sensitive information is appropriately restricted and based on individual roles. Our approach to the protection of information undergoes regular independent assurance and testing.

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Related strategic anchor: Facilitate business integrity

Challenging and enduring macroeconomic conditions expose both the banking and non-banking  sectors in Jersey to the risk of financial failure.  

Mitigation

We closely monitor the evolution of this risk through data that we collect and horizon scanning activity. A revised and refreshed approach to prudential supervision has been agreed and implementation

is continuing. This work includes delivering on our Basel III roadmap, including implementing quick wins, consulting on various elements of the Basel III framework for banks in Jersey, and publishing

our Prudential Handbook.

Risk: Registry operations

Related strategic anchor: Harness technology / Develop our people, systems, and capability

Challenges in respect of resourcing, capability, system resilience and governance hinder our ability to address service standards sustainability.

Mitigation

Underpinned by the strategic review of Registry, we are undertaking an end-to-end assessment of our Registry division, with a goal of enhancing the effectiveness of its operations, but also the ease of access of the services offered. This review will also seek to align our approach with global best practice and international standards.

77

In addition to our response to the findings from the above referenced independent review, to enhance our data protection capabilities, we also implemented several other key measures:

• appointment of a new Data Protection Officer (DPO) - we have  appointed a dedicated DPO to oversee and ensure compliance with data protection regulations. This role plays a crucial part in maintaining the highest standards of data governance
• enhanced governance arrangements - we have strengthened our governance framework by refining and updating our data protection policies and procedures. These enhancements ensure that our practices align with the latest regulatory requirements and best practice
• training and awareness - recognising the importance of

a well-informed workforce, we have enhanced our training programme to raise awareness about data protection among all employees. This ongoing education will help foster a culture of vigilance and compliance

These measures demonstrate our commitment to protecting sensitive information and maintaining the trust of our stakeholders. We are confident that the steps we have taken will significantly reduce the risk of future breaches and ensure that our data protection practices meet the highest standards of integrity and security.

78

Human rights  Anti-bribery and anti-corruption

We are committed to  Under the Financial Services Commissions (Jersey) Law 1998 we

seek to secure a proper balance between the interests of persons respecting and upholding  carrying on the business of financial services, the users of such

recognised human rights,  services and the interests of the public at large.

and the JFSC is fully  We also require relevant persons' systems and controls to prevent, compliant with Human  drieskte acst s aoncdia rteepdowrti tfihnmanocnieayl clariumned,e inricnlgu,dtienrgromriesta sfiunraensc tiong m, fiitingaanteci al

Rights (Jersey) Law 2000. sanctions, bribery and corruption, proliferation financing and

carrying on sensitive business activities.

Conflicts of interest for JFSC staff are strictly managed and are underpinned by documented and published policies, including matters that relate to share dealing, gifts and hospitality. In addition, a Board of Commissioners' Code of Conduct for conflicts of interest is externally published and is designed principally to ensure that regulatory decisions are not improperly influenced by conflicts of interest.

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Governance statement

Constitution

The JFSC is a statutory body established under Article 2 of the Financial Services Commission (Jersey) Law 1998 (FSC(J)L) which provides that the JFSC shall be governed by a Board of Commissioners comprising persons with financial services experience, regular users of such services and persons representing the public interest.

82

Accountability arrangements  

The JFSC is an independent body, accountable to the public through the island's elected representatives, namely the Minister for

External Relations and the States of Jersey. The relationship with Ministers is set out in a memorandum of understanding to ensure the independence of the JFSC, while facilitating effective dialogue and working practices. Article 12 of the FSC(J)L provides that the Minister may give the JFSC general directions in respect of the policies to be followed by the JFSC in relation to the supervision and development of financial services in Jersey and the manner in which any function of the JFSC is to be carried out, following consultation with the JFSC and where it is in the public interest to do so.

The JFSC produces an annual business plan and separately, this annual report, to inform members of the States Assembly and other stakeholders. The JFSC consults extensively on all proposals to create or amend laws and regulatory requirements and provides feedback statements to explain how responses were taken into account.

83

Governance arrangements In line with the principles of the UK Corporate

Governance Code, the JFSC's Board establishes the The Board of Commissioners (Board) maintains overall responsibility  strategy, and seeks to satisfy itself that this and its

for the governance of the JFSC, setting its strategic aims and  culture are aligned. In 2024 the JFSC continued to supporting the Executive Leadership Team to put them into effect;  progress its people strategy to further support the and holding the Executive accountable, within the scope of the  effective delivery of the JFSC's strategic objectives. FSC(J)L and the powers that the JFSC has been granted under that

law. The Board also oversees the running of the Board Committees. The Board is mindful of the level of resource

required to negotiate an ever more complex

Led by the Chair, Jane Platt, the Board believes in high quality and  regulatory environment, as well as supporting the effective governance arrangements and, in the absence of specific  need to meet international standards. It seeks to codes or standards for the governance of a financial services  ensure that the necessary resources are in place regulator, the Board follows the UK Corporate Governance Code  for the JFSC to meet its objectives and looks to

as an appropriate benchmark.  measure performance against those objectives

by way of regular reporting on key performance metrics at Board meetings.

84

In terms of the JFSC's employees, through the Remuneration Committee the Board ensures that workforce policies and practices are consistent with the company's values and support its long- term sustainable success. The JFSC's workforce is  able to raise any matters of concern via the formal route of an internal whistleblowing line or through attendance at the Staff Forum meetings. The JFSC's Staff Forum has been through a process

of formalisation, with a dedicated Chair and the formulation of a terms of reference. A number of initiatives were supported by the Staff Forum in 2024, such as educating and promoting financial regulation to primary school aged children and the Kids Executive Board.

Representatives from the Staff Forum were invited to present to the Board in 2024 and Commissioner Laurens was appointed as the Employee Engagement Commissioner, bringing the voice of the employee into the boardroom.

There is a clear division of responsibility between the Chair and the Director General, no individual has unfettered power of decision-making.

85

Delegation of powers

The Board delegates certain powers to the  Director General to ensure that the JFSC can  

run smoothly on a day-to-day basis. The Director  General is responsible for the successful  leadership of the JFSC, ensuring that Jersey's  position as an international financial centre with  high regulatory standards is maintained. In some  areas, the power of the Commissioners to delegate  is restricted by legislation. For example, the Board  acts in a similar manner to a tribunal in relation  

to contested Enforcement cases. Consequently,  the Board is more involved in some areas of detail  than a board of a listed or private company.  

A full explanation regarding the delegation  

of powers can be found on the JFSC's website:  www.jerseyfsc.org/industry/guidance-and- policy/delegation-of-powers  

86

Composition of the Board and

appointment of Commissioners A n2C0h2ae4 fir iw Cn Ool hloacwitroi, Jnbg Maenr 2e Pa0r2lk Ha3tt. D, wobeaapns au's rty Cpeptohiriaenimtr Meed inot an Aniqs pue ril The Board currently consists of the Chair, Deputy Chair and six  O'Keefe held the position of Interim Chair until

other commissioners, including the Director General. Currently  Jane's appointment. Commissioners Pichler and three quarters of the Commission Board are women. All of  Morris retired from the Board in January 2024, the Commissioners are considered to be independent, with  and Helene Narcy was appointed as a new

the exception of the Director General. A chart of the current  Commissioner in April 2024.

Commissioners is set out on page 139 of this annual report

and further information on their skills, knowledge, experience,  Recruitment of Commissioners follows a rigorous and significant interests is set out on the JFSC's website  and transparent process in line with the Jersey

at www.jerseyfsc.org/about-us/board-of-commissioners Appointments Commission's guidance and the

recruitment of the JFSC's Chair is directly overseen by the Jersey Appointments Commission.

88

    Throughout the year, the Executive and

Commissioners participated in events with

           fellow regulators, industry representatives and

     Government ministers. Frequent discussions took

place over the year with Government relating to

            significant financial services matters.

         Board members record their conflict of interests

        on the JFSC's Register of Interest and are asked

   to make annual attestations as to those entries. Furthermore, Commissioners consider the potential

          for conflicts of interest to arise in meetings and

        recuse themselves should any perceived or actual

conflict be identified. Interests are included in Commissioners' biographies on the JFSC website.

89

Board effectiveness Nomination Committee

In 2024, the Board addressed the actions of an  The Board's Nomination Committee is chaired by the Chair, external board effectiveness evaluation which had  Jane Platt. It is responsible for reviewing the structure, size

taken place in 2023, conducted by independent  and composition (including the skills, knowledge, experience expert, Fidelio. The introduction of a new Chair  and diversity) required of the Board and makes recommendations and Commissioner has provided new skill sets and  to the Board with regard to any changes.

experience. In 2024 the Nomination Committee

reviewed and refined the Board Skills Matrix  It met three times in 2024, and its principal focus in Q1 was to

to ensure that it focused on the JFSC's current  finalise the recruitment of a new JFSC Chair and Commissioner. goals and requirements, including experience in  The Nomination Committee also ensured that the Board addressed technology, administrative decision making and  the actions arising from the 2023 external Board Effectiveness sustainable finance. Evaluation and produced a revised Board Skills Matrix.

90

   Remuneration Committee

        As well as monitoring the level and structure of remuneration for          senior management (directors at grade nine and above) including

         individual performance against objectives, the Remuneration

        Committee provides advice and counsel to the JFSC's executive in     the production of remuneration policies and practices to support strategy and promote long-term sustainable success.

   Commissioner Bowes is chair of the Remuneration Committee.

        The Committee met on four occasions during the year, joined by the        Director General and the Executive Director of People and Culture.

91

Responsibility for annual report and accounts  

This annual report and accounts comply with  the requirement in the FSC(J)L which require the Minister for External Relations to lay the report and accounts before the States Assembly no later than seven months after the end of the financial year.

The statutory obligations on the Commissioners require that the annual accounts shall be prepared in accordance with generally accepted accounting principles and show a true and fair view of the surplus or deficit for the period and state of affairs at the period end. The Commissioners have elected to prepare the financial statements in accordance with Financial Reporting Standard 102 (FRS102); the Financial Reporting Standard applicable in

the United Kingdom and the Republic of Ireland.

92

The Commissioners have considered the financial statements on  pages 115-137 and are satisfied that they show a true and fair view for  the year and the financial position of the JFSC at 31 December 2024.  

As far as the Commissioners are aware, there is no relevant audit  information of which the auditor is unaware, and the Commissioners  have taken all practical steps to make themselves aware of any relevant audit information and that the auditor is aware of that information.

The Commissioners have considered the 2024 annual report and, taken as a whole, confirm that they believe the annual report is fair, balanced and understandable.

For and on behalf of the Board of Commissioners

Jane Platt

Chair

24 April 2025

PO Box 267 14-18 Castle Street St Helier

Jersey

Channel Islands JE4 8TP

94

Remuneration and  employee report

The JFSC s remuneration principles are designed to support our strategic anchor of developing our people, systems and capabilities to be a high performing organisation. We seek to attract, develop and retain high calibre individuals with diverse backgrounds and experiences and to reward them for adding value through focus

on delivering outcomes and role modelling enabling behaviours.

96

Director General remuneration

Jill Britton was not paid any fees in her capacity as a Commissioner  but was paid as an Executive Director in her capacity as Director  General. Following a benchmarking exercise and performance  review, Jill Britton received total compensation of £370,450 gross  (2023: £339,450), comprised of fixed remuneration £294,450  gross (2023: £278,250) and variable remuneration £76,000 gross  (2023: £61,200).

98

Commissioner remuneration

Commissioners receive a fixed annual amount. No additional amounts are paid for participating  in or chairing sub-committees, dealing with enforcement cases or attending to other matters.

Commissioner  2024 remuneration 2023 remuneration Mark Hoban (retired as Chair 30 October 2023) N/A £130,644 Jane Platt (Chair from 19 April 2024) £104,615 N/A Jill Britton £0 £0 Monique O'Keefe (Interim Chair until 18 April 2024) £37,045 £35,018 Simon Morris (retired 20 January 2024) £2,131 £38,325 Tracy Garrad (retired 31 December 2023) N/A £38,325 Annamaria Koerling £40,544 £38,325 Peter Pichler (retired 20 January 2024) £1,518 £27,300 Matthew Palmer £28,881 £27,300 Claire Bowes £40,544 £35,569 Megan Butler (appointed 31 May 2023) £40,544 £22,356 John Laurens (appointed 31 May 2023) £28,881 £15,925 Helene Narcy (appointed 19 April 2024)  £20,142 N/A

£344,845 £409,087

99

100

Audit and Operational   Remuneration

Risk Committee Committee

Executive Directors Committee

Staff Forum Leadership Group

Portfolio review/  Fee Income  

Project and  

Programme Board Oversight Board

Nomination  Regulatory Risk Committee Committee

Executive Risk  

Committee

Supervision Data  Information Security Collection Forum Committee

High Risk  Risk Model Business Forum Governance Forum

Financial Crime Regulatory  Horizon Scanning  

Effectiveness Committee Forum

101

Opinion

We have audited the financial statements of the Jersey Financial Services Commission (the Commission') for the year ended

31 December 2024 which comprise the Income and expenditure account, Statement of financial position, Statement of changes in accumulated reserves, Statement of cash flows, and notes to the financial statements, including a summary of significant accounting policies. The financial reporting framework that has been applied in their preparation is applicable law and United Kingdom Accounting Standards including Financial Reporting Standard 102 The Financial Reporting Standard applicable in the UK and Republic of Ireland' (United Kingdom Generally Accepted Accounting Practice)

In our opinion, the financial statements:

give a true and fair view of the state of the Comission's affairs as at 31 December 2024 and of its financial performance

for the year then ended;

are in accordance with United Kingdom Generally Accepted Accounting Practice; and

have been prepared in accordance with the requirements of the Financial Services Commission (Jersey) Law 1998.

Basis for opinion

We conducted our audit in accordance with International Standards on Auditing (UK) (ISAs (UK)) and applicable law. Our responsibilities under those standards are further described in the Auditor's responsibilities for the audit of the financial statements' section of

our report. We are independent of the Commission in accordance with the ethical requirements that are relevant to our audit of the financial statements in Jersey, including the FRC's Ethical Standard as applied to public interest entities and we have fulfilled our other ethical responsibilities in accordance with these requirements. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

Conclusions relating to going concern

We are responsible for concluding on the appropriateness of the Commissioners' use of the going concern basis of accounting

and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Commission's ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our report to the related disclosures in the financial statements or, if such disclosures are inadequate, to modify the auditor's opinion. Our conclusions are based on the audit evidence obtained up to the date of our report. However, future events or conditions may cause the Commission to cease

to continue as a going concern.

Our evaluation of the Commissioners' assessment of the Commission's ability to continue to adopt the going concern basis of accounting included review of budget forecast that included

a five year financial resilience assessment. We challenged management on the appropriateness of assumptions made

and reviewed previous budgets against actual results to assess reliability of management forecasting.

In our evaluation of the Commissioners' conclusions, we considered the inherent risks associated with the Commission's business model including effects arising from macro-economic uncertainties such as inflation, we assessed and challenged the reasonableness of estimates made by the Commissioners and the related disclosures and analysed how those risks might affect the Commission's financial resources or ability to continue operations over the going concern period.

Based on the work we have performed, we have not identified any material uncertainties relating to events or conditions that, individually or collectively, may cast significant doubt on the Commission's ability to continue as a going concern for a period of at least twelve months from when the financial statements are authorised for issue.

In auditing the financial statements, we have concluded that the Commissioners' use of the going concern basis of accounting

in the preparation of the financial statements is appropriate.

The responsibilities of the Commissioners with respect to going concern are described in the Responsibilities of Commisoners for the financial statements' section of this report.

Our approach to audit

Key audit Materiality matters

Scoping

Overview of our audit approach

Overall materiality: £530,000 (2023: £499,000), which represents 1.75% (2023:1.75%) of the Commission's revenue.

The key audit matter identified is the risk of fraud in revenue recognition and this is the same as in the previous year.

Key audit matters

Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of the financial statements of the current period and include the most significant assessed risks of material misstatement (whether or not due to fraud) that we identified. These matters included those that had the greatest effect on: the overall audit strategy; the allocation of resources in the audit; and directing the efforts of the engagement team. These matters were addressed in the context of our audit

of the financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.

Description Audit response

KAM

No material Disclosures exceptions  

were noted

We have presented the key audit matters below, together with significant risks and other risks relevant to the audit.

Key audit matter

Risk of fraud in revenue recognition

We identified the risk that revenue may be misstated as one of the most significant assessed risks of material misstatement due to fraud

Relevant disclosures in the Annual Report and Accounts 2024

Financial statements: Note 4 Regulatory fee income and Note 5 Registry fee income

Accounting policy is included in Note 1 of the financial statements.

How our scope addressed the above

In responding to the key audit matter, we performed the following audit procedures:

Our audit approach included but was not limited to: Registry fee income

We performed a walkthrough of annual confirmation fee posting on the Regsys system to understand the workflow from creation through to acceptance and posting into the NAV accounting system.

We utilised data analytics to interrogate data extracts from the myRegistry (Regsys) system to obtain all annual confirmations which were created and registered during 2024.

Transactional line items in relation to annual confirmations were then analysed to ensure that total fees for each submission were in line with the published fees on the JFSC website and that the net fee (after deduction of the government levy) is what was recorded as Revenue in totality in the general ledger.

Other transaction related fees, originating from orders placed on the portal, have been reconciled in total through to the general ledger and tested substantively.

All material revenue postings in relation to registry fees have then been analysed using data analytics to ensure that they have been credited to revenue and debited either to debtor control accounts or to the bank and covered by our balance sheet testing accordingly.

We performed cut-off procedures for both the opening and closing periods.

We additionally performed substantive procedures on deferred registry fees.

Regulatory fee income

Our approach to the audit of regulatory fee income was as follows:

Identify an entity which from our own experience received its regulatory license during the financial year. Walkthrough the data for this entity from the public registry to the list of regulated entities on the JFSC website, and then follow the license through to the underlying ERM system to ensure that the data captured is in line with our expectations and the entity was included within the 2024 fee runs appropriate for the licenses held.

Review the XML query utilised to generate the fee run for each material regulatory class.

Using data analytics to determine whether all expected entities are included within the relevant fee run and that the fee charged is consistent with the published fee notice on the JFSC website.

Perform a proof in total to determine whether all invoice lines within the ERM system have been posted to the revenue totals in the general ledger and within the correct accounting period.

We substantively tested using sampling other regulatory income of a transactional nature.

We performed a proof in total to validate the total revenue balance.

We performed cut-off procedures for both the opening and closing periods. We additionally performed substantive procedures on deferred revenue.

As a result of our work, no material exceptions were noted.

Our application of materiality

We apply the concept of materiality both in planning and performing the audit, and in evaluating the effect of identified misstatements on the audit and of uncorrected misstatements, if any, on the financial statements and in forming the opinion in the auditor's report.

Materiality was determined as follows:

Materiality measure

Materiality for financial statements as a whole

We define materiality as the magnitude of misstatement in the financial statements that, individually or in the aggregate, could reasonably be expected to influence the economic decisions of the users of these financial statements. We use materiality in determining the nature, timing and extent of our audit work.

Materiality threshold

£530,000 (2023: 499,000) which is 1.75% (2023: 1.75%) of revenue.

Significant judgements made by auditor in determining the materiality

In determining materiality, we made the following significant judgements;

We believe that revenue is the key performance measure used

by the Commissioners in assessing and reporting on overall performance by the Commission. Surplus is not a relevant benchmark as the Commission is not a profit-oriented entity but rather a public service provider. Statement of financial position items are also deemed to be inappropriate to use as benchmark given stakeholders are not interested in a return on investment made. We selected a threshold of 1.75% compared to the allowable maximum of 3% to take into account of the fact that the entity has elements of public accountability. There were no changes made to materiality levels during the audit.

Performance materiality used to drive the extent of our testing

We set performance materiality at an amount less than

materiality for the financial statements as a whole to reduce

to an appropriately low level the probability that the aggregate

of uncorrected and undetected misstatements exceeds materiality for the financial statements as a whole.

Performance materiality threshold

£371,000 (2023: £349,300) which is 70% (2023: 70%) of financial statement materiality.

Significant judgements made by auditor in determining the performance materiality

In determining materiality, we made the following significant judgements; there were few audit misstatements identified in the previous year, internal controls are deemed strong and effective, the business activities are not complex however we did not use the maximum threshold available of 75% as our planned audit approach of the income and expenditure account items was more heavily weighted toward sampling procedures.

There was no revision of performance materiality during the audit. Communication of misstatements to the audit committee

We determine a threshold for reporting unadjusted differences to the audit committee.

Threshold for communication

£26,500 (2023: £25,000) and misstatements below that threshold that, in our view, warrant reporting on qualitative grounds.

An overview of the scope of our audit

As part of designing our audit, we determined materiality and assessed the risks of material misstatement in the financial statements. In particular, we considered where management made subjective judgements; for example, in respect of significant accounting estimates that involved making assumptions and considering future events that are inherently uncertain. As in all

of our audits, we also addressed the risk of management override of internal controls, including among other matters, consideration of whether there was evidence of bias that represented a risk of material misstatement due to fraud.

We tailored the scope of our audit in order to perform sufficient work to enable us to provide an opinion on the financial statements as a whole, taking into account the structure of the Commission, the accounting processes and controls, and the industry in which the Commission operates.

Other information

The Commissioners are responsible for the other information. The other information comprises the information included in the Annual Report', other than the financial statements and our auditor's report thereon. Our opinion on the financial statements does not cover

the other information and, except to the extent otherwise explicitly stated in our report, we do not express any form of assurance conclusion thereon. In connection with our audit of the financial statements, our responsibility is to read the other information and,

in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the audit or otherwise appears to be materially misstated. If we identify such material inconsistencies or apparent material misstatements, we are required to determine whether there is a material misstatement of the financial statements or a material misstatement of the other information. If, based on the work we have performed, we conclude that there is a material misstatement of this other information, we are required to report that fact.

We have nothing to report in this regard.

Responsibilities of the Commissioners for the financial statements

As explained more fully in the Responsibility for annual report

and financial statements section set out on pages 92 to 94, the Commissioners are responsible for the preparation of the financial statements which give a true and fair view in accordance with UK GAAP, and for such internal control as the Commissioners determine is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, the Commisioners are responsible for assessing the Commission's ability to continue as

a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless the Commissioners either intend to liquidate the Commision or to cease operations, or have no realistic alternative but to do so.

Auditor's responsibilities for the audit of the financial statements

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor's report that includes our opinion.

Reasonable assurance is a high level of assurance, but is not

a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.

Explanation as to what extent the audit was considered capable of detecting irregularities, including fraud

Irregularities, including fraud, are instances of non-compliance with laws and regulations. We design procedures in line with our responsibilities, outlined above, to detect material misstatements in respect of irregularities, including fraud. Owing to the inherent limitations of an audit, there is an unavoidable risk that material misstatements in the financial statements may not be detected, even though the audit is properly planned and performed in accordance with the ISAs (UK).

The extent to which our procedures are capable of detecting irregularities, including fraud is detailed below:

We obtained an understanding of the legal and regulatory frameworks applicable to the Commission and sector in which it operates. We determined that the following laws and regulations were most significant: United Kingdom Accounting Standards including Financial Reporting Standard 102 The Financial Reporting Standard applicable in the UK and Republic of Ireland' (United Kingdom Generally Accepted Accounting Practice) and Financial Services Commission (Jersey) Law 1998;

We understood how the Commission is complying with those legal and regulatory frameworks by, making inquiries to the management. We corroborated our inquiries through our review of board minutes and committee papers provided to the Board of Commissioners;

We assessed the susceptibility of the Commission's financial statements to material misstatement, including how fraud might occur, by evaluating management's incentives and opportunities for manipulation of the financial statements. This included the evaluation of the risk of management override of controls. We determined that the principal risks were in relation to:

- risk of fraud in revenue recognition

- potential management bias in determining accounting estimates, especially in relation to the impairment of intangible assets

Our audit procedures involved:

- identifying and assessing the design effectiveness of controls management has in place to prevent and detect fraud

- understanding how those charged with governance considered and addressed the potential for override of controls or other inappropriate influence over the financial reporting process

- challenging assumptions and judgments made by management in its significant accounting estimates;

- identifying and testing journal entries, in particular any journal entries posted with unusual account combinations;

- assessing the extent of compliance with the relevant laws and regulations as part of our procedures on the related financial statement item.

We assessed the appropriateness of the collective competence and capabilities of the engagement team, which included consideration of the engagement team's;

- understanding of, and practical experience with audit engagements of a similar nature and complexity through appropriate training and participation;

- knowledge of industry in which the client operates;

- understanding of the legal and regulatory requirements specific to the Commission including the provisions of the Financial Services Commission (Jersey) Law 1998.

We did not identify any matters relating to non-compliance with laws and regulations or relating to fraud; and

In assessing the potential risks of material misstatement, we obtained an understanding of:

- the entity's operation, including the nature of its revenue sources, products and services and of its objectives and strategies to understand the classes of transactions, account balances, expected financial statement disclosures and business risks that may result in risks of material misstatement.

- the applicable statutory provisions

- the entity's control environment.

A further description of our responsibilities for the audit of the financial statements is located on the Financial Reporting Council's website at: www.frc.org.uk/auditorsresponsibilities. This description forms part of our auditor's report.

Use of our report

This report is made solely to the Minister for External Relations

of the States of Jersey in accordance with Article 21(3) of the Financial Services Commission (Jersey) Law 1998. Our audit work has been undertaken so that we might state to the Minister for External Relations those matters we are required to state to them in an auditor's report and for no other purpose. To the fullest extent permitted by law, we do not accept or assume responsibility to anyone other than the Minister for External Relations, the JFSC and the Commissioners of the JFSC as a body, for our audit work, for this report, or for the opinions we have formed.

Grant Thornton Limited Chartered Accountants St Helier

Jersey

24 April 2025

2024 2023 Notes £'000 £'000

Regulatory income

Regulatory fee income 4 24,081 21,382 Registry fee income 5 8,298 7,166 Total regulatory income 32,379  28,548

Other income 6 637  611 Interest income 597  574 Total income 33,613  29,733

Expenses

Staff costs 7 (22,566) (19,215) Computer systems (3,581) (2,482) Premises costs (1,418) (1,091) Professional services (1,241) (4,078) Investigation & litigation (142) (39) Other operating costs (1,385) (1,257) Depreciation, amortisation and impairments (1,612) (1,550) Staff learning and development (341) (229) Travel costs (140) (176) Total expenses (32,426) (30,117)

Surplus/(Deficit) for the year 8 1,187  (384)

All the items dealt with in arriving at the net surplus relate to continuing operations.

There are no recognised gains and losses in the current and preceding year other than those included in the net surplus above, therefore no separate statement of other comprehensive income and expenditure has been presented.

2024 2023 Notes £'000 £'000

Fixed Assets

Intangible assets 9 4,308  5,658 Tangible fixed assets 10 523  734

 4,831  6,392

Current Assets

Trade and other receivables 11 922  3,561 Prepayments 1,468  1,147 Cash and bank balances 12 11,905  15,073

 14,295  19,781

Total assets 19,126  26,173

Creditors - Amounts falling due after more than one year

Fee income received in advance 259  8,684 Creditors 13 5,050  4,964 Provisions 14 -  23

 5,309  13,671 Total assets less current liabilities 13,817  12,502

Creditors - Amounts falling due after one year

Fee income received in advance -  231 Creditors 13 1,198  1,180 Provisions 14 1,056  715

 2,254  2,126

Net assets 11,563  10,376 Represented by

Accumulated reserves 11,563  10,376

The notes on pages 119 to 137 form an integral part of the financial statements.

The financial statements on pages 115 to 137 were approved and authorised for issue by the Board of Commissioners on 24 April 2025, and signed on its behalf by:

Jane Platt Jill Britton

Chair Director General  116

Accumulated reserves

£'000

Balance at 1 January 2023 10,760 Deficit for the year (384) Balance at 31 December 2023 10,376

Balance at 1 January 2024 10,376 Surplus for the year 1,187 Balance at 31 December 2024 11,563

The notes on pages 119 to 137 form  117

2024 2023 Notes £'000 £'000

Cash flows from operating activities

Surplus/(Deficit) for the year 1,187  (384) Interest receivable (597) (574)

Depreciation, amortisation,

9, 10 1,796  1,550 impairment charges and write offs

Utilisation of provision

Movements in creditor provisions

Movement in doubtful debts provision Decrease/(increase) in debtors and prepayments (Decrease)/increase in income received in advance Increase/(decrease) in creditors

Net cash used in operating activities

(108) (14) 439  91

 54  57 2,264  (1,579)

 (8,656) 877  92  (1,818)

 (3,529) (1,794)

Cash flows from investing activities

Interest received 596  574 Purchases of tangible and intangible fixed assets 9, 10 (235) (238) Net cash generated from investing activities 361  336

Net decrease in cash and cash equivalents (3,168) (1,458) Cash and cash equivalents at 1 January 15,073  16,531 Cash and cash equivalents at 31 December 12 11,905  15,073

Cash and cash equivalents consists of:

Cash at bank and in hand 2,040  2,989 Short-term deposits 9,865  12,084 Cash and cash equivalents 12 11,905  15,073

The notes on pages 119 to 137 form  118

1. Significant accounting policies

Basis of preparation

The financial statements have been prepared in accordance with FRS 102, the Financial Reporting Standard applicable in the United Kingdom and the Republic of Ireland.

The financial statements are prepared on a going concern basis, under the historical cost convention.

The significant accounting policies applied in the preparation

of the financial statements are set out below. These policies have been consistently applied to both accounting years presented.

The JFSC is a statutory body established under Article 2 of the Financial Services Commission (Jersey) Law 1998.

Our registered address is Jersey Financial Services Commission, PO Box 267, 14-18 Castle Street, JE4 8TP.

We have taken advantage of the exemption available under FRS 102 section 9.3(g) and have not prepared consolidated financial statements.

Income

Income is accounted for on an accruals basis.

Regulatory annual fees received are recognised as income on

a straight-line basis over the relevant period. Annual registry fees and revenue from the operation of the Island's registers include only the share of that income attributable to us.

Amounts received from the Government of Jersey in the form of grants and other financial assistance are recognised when the JFSC has satisfied all of the conditions necessary for the funds to be released. Amounts received are recognised as income in the period in which the related costs are incurred or in the periods in which any related asset is depreciated or impaired.

Civil penalties are recognised when the penalty has been agreed with the regulated entity and where it has the ability to settle the amount involved. Income from civil penalties is deferred and is released to income in the year in which the amount of fees to be paid by Industry is reduced due to the penalty having been received.

1. Significant accounting policies (contd)

Recoveries of enforcement costs are accounted for only when they have been agreed with the regulated entity or awarded by the Royal Court and it has become virtually certain that they will be received.

Interest received on bank deposits is accrued on a time basis by reference to the principal outstanding and the effective interest rate applicable. Sundry income is recognised on receipt.

Expenses

All expenses are accounted for on an accruals basis.

Foreign currency

Foreign currency balances are translated to Sterling at the rate of exchange ruling on the last business day in the financial period. Foreign currency transactions are translated into Sterling at the rate of exchange ruling on the date of the transaction. Profits and losses on foreign exchange are included in the income and expenditure account

Investigation and litigation costs

Investigation and litigation costs are recognised as incurred. No provision is made for the cost of completing current work unless a present obligation exists at the balance sheet date.

Cash and bank balances

Cash and bank balances comprise cash in hand, deposits and other short-term liquid investments. Cash equivalents are highly liquid investments that mature in no more than three months from the date of acquisition and that are readily convertible to known amounts of cash with insignificant risk of change in value.

Financial assets

Basic financial assets, including trade and other receivables and cash and bank balances, are initially recognised at transaction price. Such assets are subsequently carried at amortised cost using the effective interest method.

At the end of each reporting period financial assets measured at amortised cost are assessed for objective evidence of impairment.

If an asset is impaired the impairment loss is the difference between the carrying amount and the present value of the estimated future cash flows discounted at the asset's original effective interest rate. The impairment loss is recognised in profit or loss.

1. Significant accounting policies (contd)

Financial liabilities

Basic financial liabilities, including trade and other creditors, are initially recognised at transaction price plus attributable transaction costs.

Financial liabilities are derecognised when the liability is extinguished, that is when the contractual obligation is discharged, cancelled or expires.

Trade and sundry creditors are obligations to pay for goods or services that have been acquired in the ordinary course of business and are classified as current liabilities if payment is due within one year or less. If not, they are presented as non-current liabilities. Trade and sundry creditors are recognised initially at transaction price and subsequently measured at amortised cost using the effective interest method.

Tangible fixed assets

Fixed assets are stated at historical cost less accumulated depreciation and any impairment losses. Historical cost includes expenditure that is directly attributable to bringing the asset

to the location and condition necessary for it to be capable

of operating in the manner intended by management.

Repairs and maintenance are charged to the income and expenditure account during the period in which they are incurred.

Depreciation of fixed assets is calculated so as to write off their cost less estimated residual value on a straight-line basis over their expected useful lives. The estimated useful lives used for this purpose are:

Motor vehicles 3 years

Leasehold improvements Over the remaining lease period

Gains and losses on disposals of fixed assets are determined by comparing the proceeds with the carrying amount and are recognised in the income and expenditure account.

1. Significant accounting policies (contd)

Intangible assets

Intangible assets are stated at historical cost less accumulated amortisation and any impairment losses. Historical cost includes expenditure that is directly attributable to the development of the intangible asset. Subsequent maintenance and support costs are charged to the income and expenditure account during the period in which they are incurred.

Amortisation of intangible assets is calculated so as to write off their cost on a straight-line basis over their expected useful lives. The estimated useful lives used for this purpose are:

Computer software Up to 7 years

The cost of computer software in respect of major systems is capitalised within intangible assets. All other computer software costs are expensed as incurred. Computer systems under development are not amortised until the system has been completed and is ready for use.

Gains and losses on disposal of intangible assets are determined by comparing any proceeds with their carrying amount and are recognised in the income and expenditure account.

In the requirements gathering phase of an internal systems development project, it is not possible to demonstrate that the project will generate future economic benefits and hence all expenditure is recognised as an expense when incurred. Systems under development are recognised as fixed assets from the development phase of a project if, and only if, certain specific criteria are met in order to demonstrate the system will generate probable future economic benefits and that its cost can be reliably measured. If it is not possible to distinguish between the requirements gathering phase and the development phase, the expenditure is treated as if it were all incurred in the requirements gathering phase only.

1. Significant accounting policies (contd)

Impairment

Assets that are subject to depreciation and amortisation are assessed at each reporting date to determine whether there is any indication that the assets are impaired. Where there is an indication that an asset may be impaired, it is tested for impairment. An impairment loss is recognised for the amount by which the asset's carrying amount exceeds its recoverable amount. The recoverable amount is the higher of an asset's fair value less costs to sell and value in use. For the purposes of assessing impairment, assets

are grouped at the lowest levels for which there are separately identifiable cash flows. Cash flows from registry and supervisory income are separately identifiable and assets are allocated between these cash flows based on their operational application.

Non-financial assets that have been previously impaired are reviewed at each reporting date to assess whether there is any indication that the impairment losses recognised in prior periods may no longer exist or may have decreased.

Leases

Rent payable under operating leases is charged to the income and expenditure account on a straight-line basis over the term of the lease.

The JFSC has taken advantage of the exemption available on transition to FRS 102 which allows lease incentives on leases entered into before the date of transition to continue to be released to the income and expenditure account on a straight-line basis over the period to the first lease break.

Pension costs

The costs of defined contribution pension schemes are accounted for on an accruals basis. The costs of annual contributions payable to defined benefit schemes operated by the Government of Jersey are accounted for on an accruals basis because we are unable

to obtain the information necessary to apply defined benefit scheme accounting.

1. Significant accounting policies (contd)

Annual leave pay accrual

A liability is recognised to the extent of any untaken annual leave entitlement which has accrued at the balance sheet date and can be carried forward to future periods. The liability is measured at the undiscounted cost of untaken annual leave that has accrued up to the balance sheet date.

Provision for long leave entitlements

Provision is made for the accrued entitlements to long leave as

at the balance sheet date, even when such entitlements may not yet have vested. The provision is increased each year as additional entitlements are earned. The provision is decreased when long leave entitlements are taken and when such entitlements expire.

The provision represents management's best estimate of the amounts expected to be paid out, taking into account long leave entitlements that may be lost when an employee leaves our employment. The provision is discounted if the effect would

be material.

Provision for premises reinstatement

Provision is made for the expected costs of reinstating office premises to their original condition upon the termination of existing lease agreements. The balance represents management's best estimate of amounts to be paid for reinstatement. The provision

is assessed each year based on changes in the expected costs of reinstatement and discount rates where applicable. The provision will be reduced when related costs are incurred in future periods. Provisions for premises reinstatement costs are discounted if the effect would be material.

2. a) Critical accounting judgements and key sources of estimation uncertainty

Estimates and judgements are continually evaluated and are based on historical experience and other factors, including expectations of future events that are believed to be reasonable under the circumstances.

Key accounting estimates and assumptions

Management is required to make estimates and assumptions concerning the future. The resulting accounting estimates may not equal the actual outcomes. The estimates and assumptions that have a significant risk of causing a material adjustment to the carrying amounts of assets and liabilities within this and the next financial year are outlined below.

Provision for premises reinstatement

The balance of the provision for premises reinstatement has been determined based on the applicable square footage of leased premises and the rate per square foot for such reinstatement

works is the high end of an indicative range provided by a local member of the Royal Institute of Chartered Surveyors without inspection of the lease or building. The provision is adjusted annually based on movements in the rate per square foot. This represents management's best estimate regarding the expected future cash flows related to these costs.

Provision for doubtful debts

Provision is made for doubtful debts when the recoverability of

a trade receivable is considered uncertain at the reporting date.

In the overall assessment of irrecoverability, management considers each amount and debtor individually as well as available information at the reporting date and any other relevant factors pertaining to the trade receivable.

Useful lives and residual values

Fixed assets and intangible assets are depreciated over their expected useful lives, taking into account residual values where appropriate. The actual lives and residual values are assessed annually and may vary depending on a number of factors. In re-assessing useful lives and residual values, a wide range of factors are taken into account. Changes in these assessments are accounted for prospectively and therefore only have a financial effect on current and future periods.

2. b) Going Concern

After reviewing the forecasts and projections, which cover the 12-month period from the date of signing the financial statements, the Board has a reasonable expectation that the JFSC has adequate resources to continue in operational existence for the foreseeable future. The JFSC has a net asset position of £11,563,000 and a stable income stream from registry and regulatory operations. The JFSC therefore continues to adopt the going concern basis in preparing its financial statements.

3. Taxation

We are exempt from the provisions of the Income Tax (Jersey) Law 1961, as amended.

4. Regulatory fee income

2024 2023 £'000 £'000

Banking

Funds

Insurance business

General insurance mediation

Investment business

Trust companies

Designated non-financial businesses and professions Recognised auditors

Money services business

2,810 2,490 9,842 9,018

1,225 1,181 293 265 1,983 1,837 4,863 4,595 3,015 1,933 34 37

16 26

24,081 21,382

5. Registry fee income

Registry fees arise from the operation of the Companies Registry, the Business Names Registry, the Registry of Limited Partnerships, the Registry of Limited Liability Partnerships, the Registry of Incorporated Limited Partnerships, the Registry of Limited Liability Companies, the Registry of Separate Limited Partnerships and the Security Interests Register.

Registry fees include annual confirmation fees. The amount of the annual confirmation fees payable to the Registry includes amounts collected on behalf of and remitted to the Government of Jersey.

In 2024 the annual confirmation fees was £330 (2023: £270)

for all entities except unregulated entities, which remained unchanged at £220. The government portion for 2024 for each annual confirmation was £175 for regulated entities and £145 for unregulated entities (2023: £145).

2024 2023 £'000 £'000

Total annual fees collected 11,359 9,676

This is apportioned as follows:

Collected on behalf of the Government of Jersey 6,274  5,437 Collected by the JFSC 5,085  4,239

11,359 9,676

Annual confirmation fee income collected by the JFSC 5,085 4,239 Other Registry income 3,213 2,927 Total Registry income 8,298 7,166

The number of annual confirmations received during the year was:

2024 2023 Annual confirmations received 37,414 37,499

6. Other income

2024 2023 £'000 £'000

Financial contribution income * 328 328 Cost recoveries** 291 286 Sundry income 18  (3)

637 611

*As detailed in note 13, an amount of £328,344 from previously segregated and deferred registry fees has been included in financial contribution income for the year ended 31 December 2024 (2023: £328,344).

**For the year ended 31 December 2024, an amount of £290,650 (2023: £288,069)

was recharged to the Jersey Resolution Authority ("the Authority") in relation to various administrative and other support services, including premises, facilities, information technology and human resources as detailed further in note 11.

7. Staff costs

2024 2023 £'000 £'000

Staff salaries

Commissioners' fees

Social security contributions

Contributions to employee pension schemes Permanent health and medical insurance Other staff costs

Long leave provision

Annual leave pay accrual

(19,210) (15,812) (345) (409)

 (960) (834)

 (1,499) (1,390) (544) (639)

 (104) (89)

- (16)

 96  (26) (22,566) (19,215)

The average number of staff employed during the year was 225 (2023: 208).

8. Surplus/(Deficit) for the year

The surplus for the year is stated after including the below:

2024 2023 £'000 £'000

Amortisation of intangible assets (note 9) (1,277) (1,280) Write offs of intangible assets (note 9) (184) - Depreciation of tangible fixed assets (note 10) (335) (270) Foreign exchange differences (18) (13) Operating lease expenditure (618) (627) Contributions to employee pension schemes (1,499) (1,390) Movement in doubtful debts (54) (57) Audit fees (63) (58)

9. Intangible assets

Computer

systems under Computer

development systems Total £'000 £'000 £'000

Cost

Balance at 1 January 2024 253  13,053  13,306 Additions 111  -  111 Completed computer systems (179) 179  - Write offs* (184) -  (184) At 31 December 2024 1  13,232  13,233

Amortisation

Balance at 1 January 2024 -  (7,648) (7,648) Charge for the year -  (1,277) (1,277) At 31 December 2024 -  (8,925) (8,925)

Net book value at 31 December 2024 1  4,307  4,308 Net book value at 31 December 2023 253  5,405  5,658

The principal expenditure during the current year was in relation to digital transformation and payroll integration. In 2023, £68,481 expenditure was incurred in relation to the implementation of new modules for the registry, risk and supervision systems.

An assessment of intangible assets was performed for the year under review and based on that, the Board decided to accelerate the amortisation of specific software assets to better reflect their expected usage and technical obsolescence. As a result of this acceleration, an additional amortisation expense recognised in the current year.

*The write off relates to software development costs for a discontinued project.

10. Tangible fixed assets

Office

furniture, Leasehold

fittings & improve- Computer

equipment ments equipment Total £'000 £'000 £'000 £'000

Cost

Balance at 1 January 2024 721 350 1,163 2,234 Additions 116 -  8 124 At 31 December 2024 837 350 1,171 2,358

Accumulated depreciation

Balance at 1 January 2024 (495) (324) (681) (1,500) Charge for the year (73) (6) (256) (335) At 31 December 2024 (568) (330) (937) (1,835)

Net book value at

269 20 234 523 31 December 2024

Net book value at

226 26 482 734 31 December 2023

11. Trade receivables

2024 2023 £'000 £'000

Trade debtors 992  2,905 Provision for doubtful debts (226) (172) Net trade receivables 766  2,733

Other debtors 87  766 Jersey Resolution Authority* 69  62

922 3,561

Provision is made for doubtful debts when the recoverability of a trade receivable is considered uncertain at the reporting date. In the overall assessment of irrecoverability, management considers each amount and debtor individually as well as available information at the reporting date and any other relevant factors pertaining to the trade receivable. At 31 December 2024, trade debtors are stated after providing for doubtful debts of £226,190 (2023: £171,729).

*On 31 January 2022, the JFSC entered into an agreement, the Master Services Agreement ("the MSA"), with the Jersey Resolution Authority ("the Authority") for the provision of various administrative and other support services, including premises, facilities, information technology and human resources. The JFSC charged the Authority a fee of £82,500 in 2024 (2023: £75,000) for the services under the MSA. During 2024 we also recharged to the Authority costs of £190,313 incurred by us on behalf of the Authority (2023: £213,069). This income has been included in Cost recoveries as detailed in note 6. The amount due to us by the Authority at the year end was £68,645 (2023: £61,597).

12. Cash and bank balances

2024 2023 £'000 £'000