Channel Islands funds update: July 2025

In our latest Channel Islands funds update, we round up recent legal and regulatory developments in Jersey and Guernsey.

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Pan-island developments

Guernsey investment statistics

The Guernsey Financial Services Commission (GFSC) has published its investment statistics for the first quarter of 2025.

The total net asset value of Guernsey funds at the end of the quarter was £278.6 billion, with closed-ended funds amounting to just under £232.8 billion and open-ended funds standing at £45.9 million. 

The last three months marked a decrease in numerical terms which is consistent with global trends.

See the statistics in full: Investment Statistics Summary First Quarter 2025 — GFSC

Jersey investment statistics

 The Jersey Financial Services Commission's (JFSC) update showed that by the end of the quarter, the value of total funds under investment management stood at £36.1 billion, showing an increase from £34.8 billion recorded in the same period of 2024.

The total net asset value of regulated funds under administration was £451.8 billion, broadly aligning with the £451.9 billion total at the end of Q1 2024. In alignment with the wider trends observed in Guernsey, the last three months also showed a decrease in these figures compared to the previous quarter.

The number of registered Jersey Private Funds (JPFs) increased to 750 in this quarter, having risen from 718 in the first quarter of last year and 730 as at the end of Q4 2024. The number of regulated collective investment funds stood at 588 by Q1 2025.

Read the statistics in full: 2025 Quarterly Reports and Statistics.

Jersey Developments

JFSC publishes 2024 annual report

On 28 April 2025, the JFSC published its 2024 annual report and financial statements. As with the JFSC's 2023 annual report, a key theme of the report is Jersey’s performance against international standards for combatting money laundering and terrorist financing. The report highlights the outcome of the 2024 MONEYVAL mutual evaluation which found that Jersey had achieved one of the highest global standards for effectiveness in preventing financial crime.

The report also covers the publication of the revised Jersey Private Fund Guide which has enhanced the appeal of JPFs to investors. It also confirms that collective investment fund application levels increased during 2024 compared to the previous year.

Other developments include the independent review of the JFSC’s fee structure by KPMG and the alignment of the JFSC's fee cycle with the financial year. The report further notes the publication of new guidance issued in respect of asset tokenisation and updated guidance on initial coin and token offerings.

For more information on the MONEYVAL report and the new and updated guidance on digital initiatives, read our October 2024 update.

View the 2024 annual report.

Financial services competitiveness programme

On 22 April 2025, the Government of Jersey announced the launch of its cross-departmental financial services competitiveness programme. The initiative is intended to reinforce Jersey’s position as a forward looking international finance centre and professional services sector.

The first phase of the programme, which is currently underway and jointly led by the government and the JFSC, focuses on enhancing Jersey’s business and regulatory environment. Subsequent phases will include a workstream led by Revenue Jersey to support the island’s international tax strategy and a global market analysis to inform Jersey's external growth strategy. The final stage will focus on Jersey’s long-term competitiveness and regulatory framework. This will involve the preparation of an independent report by global experts.

As part of the competitiveness programme, the government will consult with industry and plans to issue a progress report and accompanying action plan in spring of 2026. The government encourages stakeholders to engage with the initiative by contacting growthfs@gov.je.

View more information.

JFSC publishes performance against service level agreement  

In April 2025, the JFSC published its first quarterly service report which covers Q1 2025, outlining performance against published service level agreements. The publication of service reports reflects the JFSC’s focus on service excellence and transparency, as set out in its 2025 business plan.

The recent report includes comparative metrics across key regulatory services, including that 76.5% of personal questionnaires and 93.3% of Jersey Private Fund applications were processed within service level agreements, compared to 65.9% and 59% respectively in the same period during 2024.

The report also outlines the JFSC's improvement plans, including in relation to internal training, increased engagement with industry and the provision of guidance to stakeholders.

View the JFSC's first quarterly service report and the JFSC's business plan.

Jersey Heard podcast: insights from Emily Haithwaite on cross-border investment

In April 2025, Jersey Finance released a new episode of its Jersey Heard podcast, featuring Emily Haithwaite who heads Ogier's Jersey funds offering in the Middle East Region. In the podcast, Emily shared her insights in a conversation with Faizal Bhana (Director – Middle East, Africa, and India at Jersey Finance) and Mirek Gruna (Regional Chief Commercial Officer at IQ-EQ) on the latest developments in cross-border investment and finance structuring.

Listen to the podcast.

Consultation on disclosable beneficial ownership information 

During the second quarter of 2025, the JFSC launched a consultation on proposed changes to the information collected from legal entities in relation to their beneficial ownership. The amendments aim to enhance Jersey’s alignment with international transparency standards, whilst maintaining an appropriate balance with rights to privacy.

The consultation closed on 30 May 2025 and a feedback paper is expected during Q3.

View the consultation.

Proliferation financing national risk assessment

The JFSC has published its first national risk assessment on proliferation financing in April 2025, building on similar assessments undertaken in recent years, including those in relation to combatting money laundering and terrorist financing. The proliferation financing assessment was carried out to aid understanding of the risks of PF and to inform appropriate mitigation strategies.

The report concludes that Jersey faces a medium-low overall risk. The report outlines certain areas for development, such as enhanced inter-agency collaboration and increased awareness of proliferation financing risks and training across both public and private sectors.

People are encouraged to review the assessment and consider the findings.

Feedback on the compliance key persons regime consultation

We also reported on the JFSC’s consultation on the resourcing of compliance key persons in our October 2024 update. This consultation aimed to address recruitment challenges in the sector.

Following the closure of the consultation in December 2024, the JFSC published its feedback in April 2025. Of the 47 responses received to the consultation, 55% supported the first option proposed in the consultation: maintaining the current employment and residency requirements for key persons with targeted enhancements. The feedback indicated that resourcing pressures had eased and that significant reform was not required.

These enhancements will be progressed in collaboration with the Government of Jersey and industry as part of the financial services competitiveness programme (as outlined above).

Read the feedback in full

Consultation on AML/CFT/CPF Handbook enhancements

On 12 June 2025, the JFSC issued a consultation on proposed enhancements to the anti-money laundering/countering the financing of terrorism / countering proliferation financing (AML/CFT/CPF) Handbook. The changes aim to address MONEYVAL recommendations and improve clarity and usability for industry stakeholders.

The revised Handbook is expected to come into effect on 1 January 2026. Mapping documents and tracked changes will be published alongside the final version in November 2025.

Industry stakeholders are encouraged to respond directly to the JFSC using the online form or via Jersey Finance by 4 September 2025.

View the consultation on the JFSC proposed enhancements.

Add consultation deadline reminder to calendar.

TCSP submission guidance

The JFSC has published guidance to help trust and company service providers (TCSPs) improve the quality of Registry submissions and minimise delays.

Key reminders include: clearly identifying nominated persons, providing accurate structure charts and applying the three tier test for beneficial owners and controllers with supporting evidence and exemptions, where relevant. Submissions should use consistent full legal names and addresses, clearly describe any sensitive activities and include applicable exemptions or additional information. Where high-risk factors are present, details of the risks and mitigation measures should also be provided. 

TCSPs are encouraged to familiarise themselves with the full guidance. The JFSC also plans to release step-by-step guidance to assist entities with their submissions.

View the submission guidance.

Consultation on proposals regarding sustainable finance

In May 2025, the JFSC launched a consultation on proposed enhancements to the Codes of Practice relating to sustainability and business integrity risk, as part of Jersey’s Sustainable Finance Action Plan (covered in our January 2025 update).

For sustainability risk, the JFSC proposes new measures to embed risk management into the Codes to support firms in managing their exposure. In relation to business integrity risk, the proposals include enhancements to existing anti-greenwashing measures and their extension to additional sectors, aimed at improving transparency in advertising and strengthening market integrity. Once finalised, revised Codes will be published on the JFSC website and subject to a one-year transitional period to enable businesses to implement the changes.

A feedback paper is expected in Q3 2025 and further guidance will be provided by the JFSC.

Stakeholders are invited to respond to the consultation by 4 July 2025 using the JFSC’s online form or via Jersey Finance.

Read the JFSCs consultation on sustainable finance paper.

Add the consultation deadline reminder to your calendar.

Fees reform: Progress and next steps

We previously reported on the consultation on the JFSC fees in our January 2025 update. In May, the JFSC released an update on the reform. Key developments include:

•    Earlier publication of final fee notices (from September)
•    Alignment of all fees to the calendar year to support financial planning
•    Continued engagement with industry to inform the reform process

Next steps will consider the introduction of risk-weighted and “user pays” models and identify opportunities to maintain Jersey’s competitiveness as a leading international finance centre.

View the update.

Registry Supervision: Q1 2025 feedback

In May 2025, the JFSC published the findings of its Q1 2025 Registry Supervision inspection programme. The report outlines examples of good practice and highlights common areas of non-compliance identified during inspections and interviews.

While a small number of inaccuracies were observed, the JFSC confirmed that no systemic issues were identified. Some of the deficiencies identified include:
•    a lack of understanding of the three-tier test
•    inaccurate recording of joint ownership of shares
•    incomplete or outdated structure charts and statutory registers
•    failure to disclose individuals exercising control over a corporate trustee not regulated by the JFSC

The report also identifies a number of good practices. These include maintaining up-to-date due diligence, proactively updating records and using the myParties feature within the JFSC’s myRegistry platform. The report also notes that TCSPs that maintain detailed ownership and control records were found to have fewer findings.

Entities are encouraged to consider the findings. Read the feedback paper in full.

Guidance on obliged entity beneficial owner register

On 1 April 2025, the JFSC issued guidance on the use of the obliged entity beneficial owner register, clarifying the evidence required to demonstrate legitimate access to the register, the responsibility of entities accessing the register and discrepancy reporting.

As noted in our April 2025 update, certain individuals within obliged entities have been able to access beneficial ownership information via the myJFSC portal for the purpose of conducting customer due diligence since 24 February 2025.  Access to the register remains strictly controlled and any misuse may result in criminal penalties.

From January 2026, additional safeguards will be introduced. As part of its inspection activity, the Registry Supervision team will review a sample of audit logs to confirm that register searches have been conducted appropriately. Obliged entities will be asked to provide supporting information, such as onboarding documentation or entries in a declined business register. Entities will also be required to confirm that accessed data has not been used for any other purpose. This may be demonstrated through internal policies, correspondence records or documented explanations of use.

Obliged entities should familiarise themselves with the guidance.

Guernsey developments

Following a successful MONEYVAL assessment last year, a series of innovations in the regulatory space this quarter reveal a clear underlying message: Guernsey offers a stable environment, a robust legal and framework, accessible applications processes, and is open for business.

GFSC 2024 Annual Report: key themes

On 11 June 2025 the Guernsey Financial Services Commission (GFSC) published its Annual Report and Financial Statements for the year ended 31 December 2024, reflecting on its preparations for, and the positive outcome of, the Bailiwick’s MONEYVAL evaluation, as well as its focus on enhancing performance and streamlining processes through digital technology.

Key themes and regulatory achievements over the past year include:

• enhancement in digital infrastructure to streamline administrative processes: 

  • the release of the new Applications and Authorisations online portal (A&A portal) for the submission of regulatory applications to the GFSC Authorisations and Innovation Division

  • updates to the existing online Personal Questionnaires portal (PQ portal)

  • a further change to the PQ portal is expected to be made later this year so that individuals who begin a new Online Appointment (OA) will be prompted to update and verify the information in their PQ before they are able to proceed with the OA

• innovation in the Guernsey financial services sector:

  • the GFSC has had a number of introductory meetings regarding the potential use of tokenisation

  • notably, the GFSC granted its approval for the Bailiwick's first automated machine learning trading algorithm fund

  • potential applicants are encouraged to engage with the GFSC early on, prior to submission of an application, to help clarify expectations and manage the application process

• policy developments and simplification:

  • Guernsey successfully became a signatory to the International Organisation of Securities Commissions (IOSCO) Enhanced Multilateral Memorandum of Understanding (EMMoU) regarding information sharing in market abuse and insider dealing enquiries, one of only a handful of jurisdictions to do so, demonstrating the island's commitment to global regulatory standards

  • building on thematic review work conducted in 2023, the GFSC published guidance on unclaimed investor money to provide a principles-based and non-prescriptive frame of reference for those administering such money

  • new Regulated Investment Exchange Operator Rules to modernise and ensure compliance with the IOSCO core principles

  • taking into account the diversity of circumstances that may arise as funds enter their final stage of operation, the GFSC amended its explanatory note on fund authorisation and registration surrender, allowing for greater discretion, where appropriate, to avoid unnecessary costs or other detriment to funds and investors

• continued effort toward ongoing supervision of licensees despite dedicating significant resources to support the MONEYVAL assessment:

  • various assessments, onsite visits and thematic reviews to identify any key themes or risk areas

  • observed increase in the number of independent Non-Executive Directors (NEDs), which the GFSC considers to strengthen boards, and improvements in firms' culture, including an enhanced understanding of the difference between a functioning executive and strategic board

  • identified areas of concern include directors or trustees sitting on sub-economic structures without making adequate efforts to wind them up and firms underestimating the time and effort needed to remediate financial crime weaknesses, exit business and integrate acquisitions, highlighting the advantage of a well-considered plan over a rushed "ambitious" timeline

  • following the implementation of the OECD's Pillar Two tax regime in Guernsey, the GFSC also encourages banks to consider whether their pillar two asset stress-tests are sufficiently challenging.

Read the Annual Report in full: Commission publishes 2024 Annual Report — GFSC

The GFSC has also summarised the report in a 30-minute podcast generated using AI: Commission uses technology to create annual report podcast — GFSC

Updated Prospectus Rules

The GFSC has issued new Prospectus Rules and Guidance, 2025 (the New Prospectus Rules), to replace the existing Prospectus Rules and Guidance, 2021 with effect from 1 July 2025. The New Prospectus Rules reflect industry feedback and are designed to ensure transparency without compromising investor protection.

The principal changes are two-fold:

• the scope of application has been restricted by the introduction of numerous new exemptions which bring (among others) the following outside the scope of the New Prospectus Rules:

  • various offers of category 2 controlled investments under the Protection of Investors (Bailiwick of Guernsey) Law, 2020, i.e. general securities and derivatives which do not constitute collective investment schemes

  • promotion to an unlimited number of "professional investors" (a new category defined under the New Prospectus Rules)

  • raising the threshold for promotion to (non-professional) investors to 200 persons

  • offering securities by way of distributions or incentive schemes

• new disclosure requirements and clarificatory amendments to existing rules - to examine the changes and what they may mean for you, read our two-part briefings:

• Updated Prospectus Rules in Guernsey - part 1 | Ogier – scope of application and new exemptions for offers of general securities

• Updated Prospectus Rules in Guernsey - part 2 | Ogier – changes to disclosure requirements
  
  

View the new Prospectus Rules here: The Prospectus Rules and Guidance, 2025

GFSC's position on crypto currency funds

Reaffirming Guernsey's pro-innovation stance and noting that bitcoin and other digital assets are entering a more mature phase, the GFSC has confirmed that collective investment schemes can, when appropriately run, provide vehicles for a range of investors to invest indirectly in crypto currencies, provided that the investor is well informed of the risks and is able to bear any potential losses. 

The statement indicates a more permissive approach to crypto currency funds and their suitability to institutional and retail investors (with appropriate protections). It also contains new guidance on factors the GFSC would consider as part of the regulatory application process.

The guidance aligns well with Guernsey's existing fund structuring options, particularly the new Private Investment Fund Rules and Guidance, 2025 (the New PIF Rules), which are well suited to both experienced institutional investors and family and friends structures seeking digital asset exposure.

Read our article outlining the GFSC's guidelines.

View the GFSC's statement: The Commission’s approach to crypto currency funds — GFSC

Enterprise risk management for solvency purposes: positive result for Guernsey

Guernsey has achieved a positive evaluation in the Association of Insurance Supervisors (IAIS) peer review process focused on how insurers manage risk relating to solvency, which assesses enterprise risk management for insurers. 

The review represents a point-in-time assessment with a view to showing any gaps in a jurisdiction’s supervisory and regulatory frameworks in relation to the IAIS Insurance Core Principles (ICPs). ICP 16, relating to enterprise risk management for solvency purposes, is one of 25 ICPs that collectively form the globally accepted framework for insurance supervision.

Guernsey was one of 67 authorities to participate in the peer review process of ICP 16. 

The review concluded that Guernsey largely observes ICP 16, meaning that any shortcomings identified are minor and there are no concerns with Guernsey’s ability to achieve full observance.

Read a detailed summary of the results: Guernsey performs well in global peer review of enterprise risk management for solvency purposes — GFSC

New Private Investment Funds regime replacing existing PIF Rules

The GFSC has overhauled its private investment funds (PIFs) regime, replacing the Private Investment Fund Rules and Guidance (2), 2021 with the New PIF Rules with immediate effect. The New PIF Rules create a flexible and light touch regulatory category suitable for a wide spectrum of private capital investment strategies, available for both open-ended and closed-ended funds.

Key features of the regime include:

• the three PIF routes under the previous regime have been reworked into two types of PIF: Qualifying PIFs (QPIF) and Family PIFs

• unlimited number of offers may be issued

• unlimited number of investors

• new and broader categories of investors eligible to invest in a PIF

• no requirement to appoint an auditor

• no requirement to issue a prospectus

• regulatory approval in as little as 24 hours

The New PIF Rules offer a regulated product with appropriate regulatory oversight, together with enhanced speed to market, flexibility and adaptability to a variety of investment structures and investor categories.

Read our comprehensive summary of the New PIF Rules: Guernsey Private Investment Funds: 2025 updates | Ogier

Amendments to the Financial Crime Returns Rules

Following the recent consultation, the GFSC has published updated Financial Crime Returns Rules, 2025 making it mandatory for accountants, lawyers and estate agents (prescribed businesses previously exempt) to file periodic returns, standardising obligations across financial services business sectors.

The new rules are in force as of 2 May 2025.

Read the new rules in full: Financial Crime Returns Rules, 2025.

New address for the GFSC

The GFSC's new postal address is:

Guernsey Financial Services Commission
Regency Court
Glategny Esplanade
St Peter Port
Guernsey
GY1 3HQ

Updates to the AML / CFT / CPF Handbook – pooled accounts

On 2 May 2025 the GFSC made amendments to the guidance on pooled accounts in Chapter 9 of the Handbook on Countering Financial Crime (Anti-Money Laundering / Countering the Financing of Terrorism / Countering the Financing of Proliferation of Weapons of Mass Destruction) (the Handbook) to address an anomaly in the way in which the Handbook treats pooled accounts operated by subsidiary companies of investment and fiduciary licensees.

The clean and tracked versions of the Handbook can be accessed via the Handbook page.