Snapshot: New Sound Business Policy in Jersey

The Government of Jersey and the Jersey Financial Services Commission have jointly issued the newly renamed Sound Business Policy (previously the Sound Business Practice Policy), which came into effect on 1 November 2025.

The updated Sound Business Policy (SBP) is intended to be more concise and accessible, with substantial simplifications to the policy. Financial service business activities are no longer automatically considered sensitive, as reflected in the removal of the former Table 1 of the Sound Business Practice Policy (SBPP). However, such applicants are still required to give the SBP consideration when completing their customer and business risk assessments.

A key part of revising the policy involved reassessing activities that might present a reputational risk to Jersey. Previously, these were set out in Table 2 to the SBPP but are now included in a single Table attached to the SBP. Following input from a broad range of stakeholders, six categories have been removed, including the cultivation, production, supply, use, export, or import of cannabis or any of its derivatives and involvement in initial coin offerings or the provision of other services relating to virtual assets. This approach recognises that other laws and regulatory frameworks now provide sufficient oversight in relation to those areas.

The five activities that remain subject to particular scrutiny as set out in the Table to the SBP are:

• defence (focusing on controversial, restricted and prohibited arms)
• pharmaceuticals (if unlicensed)
• dual use goods
• mining, drilling and quarrying
• financial services business (where it is regulated in Jersey but not in the 'target market' where those activities are being undertaken)

Definitions and guidance for each category have been updated to provide clarity and help applicants understand the SBP's requirements. Further guidance on the scope of the activities caught can be expected from the JFSC, given how broad the descriptions of the activities are.

This measured set of changes is designed to make it easier for businesses to understand regulatory expectations in Jersey, while reassuring stakeholders that Jersey continues to maintain a commercial environment that is both well-regulated and competitive.

Read the JFSC's Sound Business Policy in full.

What should you do next?

Jersey regulated business should review their policies and procedures to take account of the revised policy, noting that the removal of certain activities from the SBP won't automatically mean they should no longer be considered high-risk.

How Ogier can help

Ogier has one of the leading contentious and non-contentious regulatory practices in Jersey with lawyers specialising in local and cross-border regulatory advice. We regularly advise funds, asset managers, banks and financial institutions on Jersey regulatory matters, including in relation to the promotion of closed-ended investment funds to Jersey resident investors or via Jersey IFAs and distributors.

For more information about any of the above, reach out to Sophie or any of our Jersey funds specialists.

About Ogier

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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