Jersey LLCs: revisions to permitted uses

The Jersey Financial Services Commission has updated its guidance on limited liability companies (LLCs) to remove restrictions on their use for certain regulated financial services business.

It is expected that the revisions^[1] will encourage a wider use of Jersey LLCs, particularly among US asset managers.

In this snapshot, our Jersey law specialists summarise what financial services providers need to know in practice about the updated permitted uses for Jersey LLCs.

Notably, Jersey LLCs can now:

• act as corporate trustees, given LLCs have separate legal personality and are able to hold assets and enter into contractual relationships in the same way as companies

• conduct specified classes of financial services business (including fund services business, trust company business and investment business) under the Financial Services (Jersey) Law 1998 (FSJL) and accordingly act as the manager or investment manager of a collective investment fund

The restriction limiting the use of LLCs to financially sophisticated investors or customers has also been removed, on the basis that administration services to the LLC must be provided by a regulated trust company business so that any associated risks are appropriately managed.

LLCs can continue to be registered as Jersey Private Funds. However, they are still restricted from conducting certain regulated activities, namely:

• being authorised as “collective investment funds” under the Collective Investment Funds (Jersey) Law 1988

• conducting banking business under the Banking Business (Jersey) Law 1991

• conducting insurance business under the Insurance Business (Jersey) Law 1996

The Limited Liability Companies (Jersey) Law 2018 was modelled on its US counterpart, to ensure familiarity to US advisers and sponsors. Accordingly, an LLC is largely governed by the terms of its LLC agreement which ensures flexibility to reflect the parties' requirements in terms of management, economics and distributions. Members have limited liability and, at registration, an LLC can choose to be either a body corporate or an unincorporated body.

For a summary of the main legal requirements applicable to the formation, registration, operation and winding up of a Jersey LLC, read our earlier briefing:

Jersey limited liability companies (LLC)

Trust companies providing services to LLCs (for example acting as formation agent, providing a registered office, acting as a member or manager) must hold the appropriate classes of registration for trust company business under the FSJL.

For more information on Jersey LLCs, including the recent guidance update and wider regulatory and structuring considerations, contact our team.

^[1]Updated Guidance effective as of 14 October 2026 – Limited liability companies – regulatory considerations — Jersey Financial Services Commission

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Disclaimer

This client briefing has been prepared for clients and professional associates of Ogier. The information and expressions of opinion which it contains are not intended to be a comprehensive study or to provide legal advice and should not be treated as a substitute for specific advice concerning individual situations.

Regulatory information can be found under Legal Notice