Channel Islands funds update: July 2026

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

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Jersey developments

Companies Law Amendments 

As referenced in our April Channel Islands Funds update, the Companies (Jersey) Amendment Law 2026 came into force on 1 June 2026.   

Following on from this, the Companies (Jersey) Amendment No. 2 Law 2026 came into force on 19 June 2026 (the Amendment No. 2 Law). This Law forms the second phase of Jersey’s 2026 company law reforms and introduces a new court supervised corporate administration regime into the Companies (Jersey) Law 1991. 

The core objective of the regime is to provide a formal restructuring and rescue tool for distressed companies. This allows the Royal Court to appoint an administrator where this is likely either to preserve the business as a going concern or to achieve a better outcome for creditors than an immediate winding up.  

In practical terms, this is a significant addition to Jersey’s insolvency toolkit. It aligns the jurisdiction more closely with the UK and other leading financial centres by providing a flexible restructuring option alongside existing winding‑up procedures.  

Alongside the Amendment No. 2 Law, the Companies (Secured Creditors and Notice of Application for Administration Order) (Jersey) Order 2026 came into force on 24 June 2026 and requires that secured creditors receive notice of an application for an administration order and preserves their enforcement rights notwithstanding the broader moratorium.  

Further information is available in Ogier's client advisory: Jersey introduces new corporate administration regime | Ogier

Director Disqualification Sanctions (Jersey) Amendment Law 2026 

As noted in our April update, the Director Disqualification Sanctions (Jersey) Amendment Law 2026 took effect on 22 June 2026. The Law introduces a prohibition on appointing any person who is subject to director disqualification sanctions — as defined in Article 5A(1) of the Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021— as a director of a company incorporated under the Companies (Jersey) Law 1991 (by amending Article 78A of that Law). It similarly amends Article 28A of the Limited Liability Companies (Jersey) Law 2018 to prohibit the appointment of any such person as a manager of a limited liability company. 

Proceeds of Crime (Cannabis Exemption – List of Jurisdictions) (Jersey) Amendment Order 2026  

This Order, which came into force on 6 July 2026, amends the Proceeds of Crime (Cannabis Exemption – List of Jurisdictions) (Jersey) Order 2021 by inserting South Africa into the Schedule of recognised jurisdictions. The effect of this amendment is that the lawful production, supply, use, export or import of cannabis and any of its derivatives taking place in South Africa will not constitute criminal conduct for the purposes of the Proceeds of Crime (Jersey) Law 1999. 

JFSC and Registry changes 

As a result of the Companies Law reforms, the Jersey Financial Services Commission (JFSC) has updated its Registry forms and submission processes. These changes are primarily operational, ensuring that filings (for example, constitutional changes, share capital adjustments and governance updates) align with the revised statutory framework.  

The JFSC has also issued industry updates signalling further refinements to forms and filing requirements to support the modernised Companies (Jersey) Law regime.  

These updates form part of the Registry’s wider “digital‑first” and simplification agenda, aimed at reducing administrative friction and aligning filing processes with the substantive law reforms. 

More exchanges and markets added to Jersey’s Listed Fund Guide 

The JFSC has updated the Jersey Listed Funds Guide (Schedule 3) to expand the range of recognised exchanges and markets available to Jersey listed funds, with effect from 1 June 2026.  

The update aligns the Listed Funds regime with recent changes to the Companies (Jersey) Law 1991 referenced in our April update and the listed company framework and revises Appendix 1 to broaden the definition of recognised stock exchanges and markets.  

Jersey listed funds can now be admitted to: all European Free Trade Association (EFTA) regulated markets; and a wider range of additional exchanges referenced in the UK Financial Conduct Authority’s recognised and designated exchange lists. This materially increases the total number of eligible markets.  

Simplifying the regulatory framework to support growth  

The JFSC has launched a regulatory simplification programme as part of its 2026–27 business plan, aimed at making the framework easier to access, understand and apply consistently. 

Initial measures include:  

• introduction of principles for drafting regulatory materials  
• a new consultation charter clarifying engagement expectations  
• updates to guidance notes (including consolidation and removal of outdated materials), without introducing new substantive requirements 

The initiative is focused on improving usability rather than changing regulatory standards, with an emphasis on clarity, proportionality and consistency.  

Faster decisions to support applications  

The JFSC has introduced updated service level agreements (SLAs) with reduced processing times across a range of authorisation and registration applications, reflecting a focus on efficiency and transparency.  

The revised SLAs are underpinned by a risk‑based approach, with lower‑risk applications benefiting from accelerated timelines while higher risk or complex cases continue to receive more detailed review.  

The changes are intended to improve speed to market, provide clearer expectations on timelines and enhance overall service delivery, including significant reductions in turnaround times for certain licensing and Schedule 2 applications.  

These updates reflect a continued emphasis on proportionate regulation and operational efficiency, aligning supervisory effort more closely with risk.  

Q1 2026 service report 

The JFSC’s Q1 2026 service report shows improved performance across most service areas, with higher proportions of applications processed within SLA and reduced processing times.  

Reported improvements include:  

• increased compliance with SLAs for regulatory and Registry services  
• faster processing times, with some application types reduced from approximately 20 to 10 working days  
• strong performance across high‑volume areas such as company incorporations and fund applications  

The report forms part of a commitment to greater transparency, with the JFSC publishing quarterly performance data against service standards.  

The data evidences measurable progress in delivering service excellence and speed to market, consistent with the JFSC’s strategic focus on competitiveness. 

Focus examinations — targeted supervisory approach  

The JFSC has introduced focus examinations as a new supervisory tool, designed to assess compliance in specific, clearly defined areas without the scope and disruption of a full examination.  

Key features include:  

• minimal documentation requirements (limited to essential extracts from relevant documents) 
• short onsite reviews that typically last around half a day  
• an interactive format allowing firms to demonstrate processes in practice 
• tailored and industry‑wide feedback to highlight good practice and common issues  

The first examinations will focus on targeted financial sanctions, with rollout having commenced in June 2026.  

This approach reflects a shift toward more agile, proportionate supervision, complementing existing thematic and financial crime examinations.  

2025 JFSC financial crime examinations feedback

The JFSC have published its 2025 financial crime examinations feedback paper, which sets out the key findings from financial crime examinations conducted during 2025. The paper provides useful insight into the areas of focus for the JFSC and highlights common themes and areas for improvement identified across regulated entities. 

JFSC consultations 

Intellectual property registration fees  

On 1 June 2026, the JFSC launched a public consultation on proposed fees for a new Jersey intellectual property (IP) register. The register is scheduled to go live on 1 August 2026 as part of wider modernisation of the Island’s IP framework.  

The consultation covers proposed fee structures for the registration of trademarks, patents and designs, and invites feedback from industry stakeholders.  

The deadline for submissions is 30 June 2026. 

This initiative forms part of Jersey’s move to implement a standalone, modernised IP registration system, with the consultation focusing on ensuring that the associated cost framework is proportionate and does not unduly discourage use of the new register.  

Guidance on Limited Liability Companies 

On 25 June, the JFSC launched a consultation on targeted updates to its guidance on limited liability companies (LLCs).   

The JFSC is proposing four main changes to the current guidance: 

• allow LLCs to act as corporate trustees to align with updates to the Trusts (Jersey) Law 1984 and remove uncertainty about whether LLCs can fulfil this role 
• allow LLCs to be used for certain regulated activities under the Financial Services (Jersey) Law, without changing the existing authorisation process 
• remove the "financially sophisticated investor" restriction so LLCs would no longer be limited to financially sophisticated investors or customers, making the structure more accessible while maintaining existing regulatory protections 
• improve clarity and accessibility of the guidance to make it clearer, easier to follow and more proportionate 

These changes aim to support wider use of LLCs and ensure the guidance is simple, clear and consistent. 

The consultation is open for comment until 12pm on Thursday 6 August. 

JFSC: AML/CFT/CPF Handbook  

Following our April update, the JFSC has issued a single updated AML/CFT/CPF Handbook (the Handbook), effective 31 May 2026, along with a separate, simplified handbook for non‑profit organisations. 

Complex structures 

The updated Handbook confirms a more practical approach to complex structures: 

• indicators of complexity are only guidance (not strict rules)
• a structure being complex does not automatically mean it is high risk or requires enhanced due diligence 

What has changed overall? 

Since the consultation, the JFSC has: 

• brought all recent updates together into one clearer, more consistent Handbook 
• made targeted changes to criminal background check rules to improve clarity
• introduced a simplified handbook for non-profit organisations

Criminal background checks (simplified) 

The updates mainly clarify how existing requirements should be applied, rather than introducing new obligations. 

Key points: 

• The rules now clearly apply to “principal persons and key persons” (that is, the relevant senior individuals), removing ambiguity about who is covered 
• The wording across the Handbook has been aligned so requirements are applied consistently
• It is now clearer when criminal record checks are required 
• References to roles like Deputy MLRO / MLCO have been removed to simplify the framework 

No new category of checks has been introduced, and the aim is simply to ensure firms are applying the rules consistently and to the right people. 

Firms should check that internal processes correctly identify principal and key persons and ensure that the timing and scope of checks match the clarified guidance. 

Changes to Section 2.6 (MLCO) 

As referred to in our April update, on 30 June 2026, the JFSC updated section 2.6 of the Handbook, in line with updates to the Money Laundering (Jersey) Order 2008 made on 17 April 2026 (the Order).  

The updated MLCO section is due to take effect on 30 June 2026, with the live Handbook to be updated on that date.  

The JFSC has published a tracked-changes version of Section 2.6 to help industry prepare: draft section 2.6 - AML/CFT/CPF Handbook. 

Some additional changes to the Order are not yet reflected in the Handbook, including: 

• the introduction of a risk-based approach to appointing an MLCO – this will be available from 31 October 2026, once the Handbook is updated 
• changes to the Reliance framework – these are already in the Order and will also take effect from 31 October 2026 

These further updates will be subject to consultation, details of which will be published in early July. 

Countries and territories in AML/CFT/CPF Handbook appendices updated 

On 19 June 2026, the JFSC updated appendix D1 and D2 of the AML Handbook in response to the latest Financial Action Task Force (FATF) statements of 19 June 2026. 

The changes are as follows: 

Appendix D2 amendments – 19 June 2026  

• deleted from the list of countries and territories: Namibia  
• source 2 added: Bosnia and Herzegovina and Iraq   
• source 2 removed:  Algeria and Namibia 

Effective immediately, countries and territories listed under Sources 1 and 2 of Appendix D2 should be treated as not compliant with FATF Recommendations for the purpose of Article 17A of the Money Laundering Order. 

Changes to the reliance and money laundering compliance officer regimes

On 7 July 2026, the JFSC issued a consultation on changes to the reliance and money laundering compliance officer regimes.  

The proposed changes are driven primarily by amendments made to the Money Laundering (Jersey) Order 2008 (the MLO) in April 2026, and form part of the broader Financial Services Competitiveness Programme being undertaken in conjunction with the Government of Jersey.

The stated objective of the consultation is to simplify and modernise the existing requirements, with a view to reducing compliance costs for industry whilst maintaining a proportionate, risk-based approach to managing financial crime risk. The JFSC has indicated that it intends to introduce greater flexibility and reduce unnecessary operational burdens on supervised persons.

The key proposals relate to amendments to the Codes of Practice and associated guidance in two principal areas:

Money Laundering Compliance Officer (MLCO): 

• The JFSC proposes to allow supervised persons to dispense with the requirement to appoint an MLCO where this is appropriate having regard to the size and risk profile of the business. In addition, the proposals would permit the decoupling of the MLCO's responsibility from the operational compliance monitoring function, including by way of support arrangements.

Reliance regime:

• The JFSC proposes to adopt a more practical, risk-based approach to reliance under Articles 16 and 16A of the MLO. This reflects, in particular, the removal of mandatory testing requirements under recent amendments to the MLO. 

The consultation closes at 17:00 on 18 August 2026. 

Feedback published on civil financial penalty methodology  

Following the consultation referenced in our April update, the JFSC has now published its feedback paper and finalised amendments to the civil financial penalties methodology for registered persons.  

As outlined in the earlier consultation, the proposed changes were driven by the Financial Services Commission (Financial Penalties) (Jersey) Amendment Order 2026, which reintroduced monetary caps for Bands 1, 2 and 2A and a series of targeted refinements to improve clarity and reflect the JFSC’s operational experience in applying the regime.  

Respondents generally supported the need to align the methodology with the updated legislative framework and welcomed greater transparency, including explicit reference to the best economic interests of Jersey as a guiding principle. However, some stakeholders raised concerns that aspects of the draft could be interpreted as more prescriptive or stringent, particularly in relation to mitigation (including voluntary reporting and remediation) and the overall flexibility of the regime.  

In response, the JFSC has made targeted drafting changes to address these concerns, while confirming that the methodology remains a guideline framework (not a checklist) and it will continue to be applied flexibly and proportionately on a case‑by‑case basis.  

The finalised methodology also retains and clarifies guidance in key areas, including:  

• voluntary reporting and remediation
• settlement discounts  
• the structured assessment steps used to calculate penalties

Guernsey developments 

Launch of the Fund Foundry 

Guernsey-based non-profit Foundry Partners (LBG) has launched the Fund Foundry, the first programme of its kind in the Crown Dependencies. It aims to eliminate entry barriers for fund managers across all asset classes. 

The Fund Foundry selects five managers each year following a competitive application process and awards each of them:  

• a £25,000 service voucher redeemable against legal, administration and audit costs in the first year 
• registration of their funds with the Guernsey Financial Services Commission (GFSC) pathway 
• opportunities for interactions with prospective investors 
• a structured support package taking their idea from concept to launch, including connecting them with a mentor from an established fund manager 

Ogier is delighted to be a service provider sponsor of the Fund Foundry and to have moderated its kick-off seminar at the Guernsey Funds Forum. 

Investment Funds partner Tim Clipstone commented: “The Fund Foundry builds on Guernsey’s established reputation for assisting new and emerging managers build their fund platforms in a cost effective, highly respected and well-regulated jurisdiction giving them great access to investors in all key markets across the globe."

Applications are now open until 1 September 2026. The finalist event will be held from 23 to 25 September 2025. Register at The Fund Foundry.

First dual-designated sustainable fund 

The Guernsey Financial Services Commission (GFSC) has registered the first fund to qualify under both designations of Guernsey's Sustainable Funds Regime: as a Guernsey Green Fund and a Natural Capital Fund. 

The dual designation reflects the fund's investment strategy focused on solar energy infrastructure and its objectives to generate clean electricity while also seeking to benefit nature. 

See our briefings on the Guernsey Green Fund and the Natural Capital Fund: 

At a glance guide to Guernsey Green Funds | Ogier

At a glance guide to Guernsey Natural Capital Funds | Ogier

Guernsey receives WealthBriefing Sustainability Award 

Guernsey has won the Sustainability Programme (UK) category at the WealthBriefing Wealth for Good Awards 2026. 

The GFSC recognised that the award reflects the sustainability regulatory initiatives, including: 

• the Guernsey Green Fund 
• the Natural Capital Fund 
• the green capital regime in the insurance sector 

It is also due to the island's track record in humanitarian catastrophe bonds, reinsurance structures and responsible captive insurance structures.

GFSC 2025 annual report 

The GFSC has published its annual report and financial statements for the year ended 31 December 2025. Key takeaways for firms are summarised below. 

Authorisations and digital innovation 

The GFSC reported a number of developments aimed at supporting digital innovation and improving regulatory engagement. 

A key initiative has been the launch of Launch of the Digital Finance Initiative, comprised of three elements:  

• the Digital Forum 
• the Digital Finance Regulatory Strategy which includes, including proposals for regulating stablecoins, tokenised funds, digital and tokenised assets, and adapting the financial crime framework to the use of such technologies  
• Innovation Sandbox + Concierge 

The GFSC note there are ideas in development through the Innovation Sandbox + Concierge service, which builds on its predecessor, the Innovation Sandbox. It offers a structured framework for engagement with the GFSC for the regulation of digital and other innovative financial products. The Concierge element provides an opportunity to connect firms with other Guernsey agencies on an as-needed basis.

The GFSC also continues to develop its Applications and Authorisations Portal. Applications increased by approximately 5% compared to the previous year, with private investment fund applications recording the strongest results since their launch in 2017. The GFSC noted that most industry respondents considered the portal an improvement on the previous applications process. 

Further reflecting on its focus on innovation, the GFSC established both a Technology Innovation Unit and a Technology Supervision Unit. The latter has attended onsite visits, contributed to firm risk assessments and assisted the Authorisations and Innovation Division when considering new applications.   

Commenting more generally, the GFSC observed that Guernsey licensees are not currently at the cutting edge of AI or digital development and that businesses will miss out if they do not develop and deploy technological enhancements.

Supervisory engagement

The GFSC reiterated the importance of continuous compliance by licensees with the minimum criteria for licensing and exercising mind and management in Guernsey. 

Licensees should have in place contingency and succession plans to remain in compliance with the minimum criteria for licensing. The GFSC recognises the value of non-executive directors willing to challenge and support executive directors. 

The GFSC noted occasional cases where local firms are being pushed by wider groups into ill-timed acquisitions or amalgamations, weakened controls, decisions that are not in the best interests of the local licensee or reliance on outsourced functions without sufficient oversight. 

The GFSC further emphasised the importance of being open and cooperative with the regulator and encouraged firms to propose next steps when communicating a problem.

Banking 

In 2026 the GFSC will commence establishing and making operational the new Banking Resolution Committee as a distinct part of the GFSC. It will be responsible for ensuring that depositors are appropriately protected in case of failure of a "Domestic Systemically Important Bank". 

Among the key risks identified for 2026 are: 

• the continuing need to adhere to developing financial crime requirements 
• stress testing for more challenging economic conditions, not least around credit (in a downturn) and currency (given continued geopolitical uncertainty) 
• bond price volatility, not least as it affects liquidity profiles 
• financial crime, scams and cybercrime 
• treatment of customers, not least around account opening and closing 
• lending standards in the context of lending, credit and finance legislation 

Guernsey investment statistics 

The GFSC has published its investment statistics for the first quarter of 2026. 

The total net asset value (NAV) of Guernsey funds remained substantially unchanged from the previous quarter at £272.6 billion (down by £0.2 billion or -0.1%). 

Within this total, the NAV of Guernsey closed-ended funds increased by £4.5 billion (+2.0%) to just under £229 billion, while Guernsey-domiciled open-ended funds NAV decreased by £4.8 billion (-9.9%) to £43.6 billion. The NAV of Guernsey Sustainable Funds was £4.4 billion at the end of the quarter. 

ODPA statement on verification of information from AI 

The Bailiwick Data Protection Commissioner has issued a statement highlighting the importance of verifying the information derived from AI. This follows a complaint received from an individual whose name had been wrongly associated with the criminal conduct of another person (due to a shared surname) in an AI‑generated summary produced by a search engine’s automated results feature. 

The statement emphasises that AI systems must never replace human judgement and verification is particularly critical when AI is applied to personal data, especially in open‑ended contexts like search results. 

The Office of the Data Protection Authority in Guernsey assisted the individual with rectifying the information provided by the search engine provider.

Positive result for Guernsey in IAIS reinsurance and risk transfer global peer review 

The Bailiwick of Guernsey has achieved a positive result in the peer review process of the International Association of Insurance Supervisors (IAIS), examining how insurers manage their use of reinsurance and other forms of risk transfer. The review aims to provide a point-in-time assessment of a jurisdiction’s supervisory and regulatory frameworks against the IAIS Insurance Core Principles. 

The review team did not identify any major gaps in Guernsey’s observance of ICP 13, placing Guernsey alongside 26 other participating jurisdictions that achieved the highest level of assessment.

Guernsey part of UK-Gulf Free Trade Agreement 

The States of Guernsey have announced that the Free Trade Agreement between the United Kingdom and the Gulf Cooperation Council (GCC), concluded on 20 May 2026, will include the Bailiwick of Guernsey for goods and key elements relating to financial services. 

The GCC includes Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United Arab Emirates. 

OECD Pillar Two GloBE Model Rules applicable in Guernsey from 2026 

Following a recent statutory update, the OECD Global Anti-Base Erosion Model Rules (Pillar Two) (the GloBE Rules) will apply in respect of the fiscal year 2026 and subsequent fiscal years.  

The GloBE Rules impose top-up tax on profits of multinational enterprise groups (MNE Groups). With annual revenue above certain thresholds, when the effective tax rate in a jurisdiction in which they operate is below the minimum level. As a result, MNE Groups will be subject to a minimum level of tax on the income arising in each of the jurisdictions they operate in. 

In Guernsey, the GloBE Rules are transposed in the Income Tax (Approved International Agreements) (Implementation) (OECD Pillar Two GloBE Model Rules) Regulations, 2024 which provide for a domestic top-up tax and multinational top-up tax. 

Supporting growth with digital finance feedback paper 

The GFSC has published an initial feedback paper following its consultation on Supporting Growth with Digital Finance: Enhancing Anti-Financial Crime Controls with Technology. The basis for the consultation was the recognition that the use of technology can aid with compliance processes such as customer due diligence, ongoing monitoring and scrutiny of transactions, adverse media and sanctions screening and record retention. 

The feedback paper focuses on the responses received to question 8.1 of the consultation: "Do respondents agree with the proposed changes to the Handbook? If not, what other changes are suggested?"  

The responses received form the basis for the recent revision 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), covered below. 

This feedback paper represents the first phase of the GFSC's response to the consultation. Further feedback will be published in due course. 

AML / CFT / CPF Handbook: the use of technology for compliance 

The GFSC has updated the Handbook to take into account the feedback received in the consultation on Supporting Growth with Digital Finance: Enhancing Anti-Financial Crime Controls with Technology and align terminology in the Handbook with the Electronic Transactions (Guernsey) Law, 2000. 

A number of changes have been made throughout the Handbook and its appendices with the objective of supporting the use of technology to combat financial crime. It includes guidance on how tools such as electronic verification systems and digital signatures can be used. 

The GFSC also intends to introduce updates to the Handbook to incorporate MONEYVAL’s recommended actions, which will be subject to separate consultation. 

In line with updates to the Financial Action Task Force’s (FATF) list of jurisdictions under increased monitoring, Iraq and Bosnia & Herzegovina have been added to, and Namibia has been removed from, the Appendix I list of higher risk jurisdictions. Algeria has been removed from FATF's list but it remains in Appendix I of the Handbook because it remains listed in other relevant sources.

The clean and tracked versions of the Handbook and its Appendices can be accessed via the GFSC's Handbook page. 

Equity release regime comes into force 

The Lending, Credit and finance (Equity Release Mortgages) (Guernsey) Ordinance, 2026 came into force on 1 May 2026. The ordinance amends Guernsey customary law to enable lifetime mortgages secured against real property in Guernsey and used for residential purposes to be created, maintained and enforced.  

Lifetime mortgage (defined in the Lending, Credit and Finance (Bailiwick of Guernsey) Law, 2022) is a class of equity release finance under which full repayment of the capital is not due until a "lifetime event". This includes the customer's death or the customer selling the property or acquiring another property as their main residence, or leaving the property to live elsewhere with no reasonable prospect of returning.

Licensees to review technology risk management arrangements

The GFSC Director of Technology has issued a letter to the boards and senior management teams asking licensees to review their technology risk management arrangements, including vulnerability management, patching processes and third-party oversight.

The regulator has addressed the opportunities and risks of the use of artificial intelligence (AI) in the cyber risk space. AI has proven increasingly capable of identifying software vulnerabilities across digital infrastructure. This brings both opportunities for innovation and risks for firms. With the help of AI it is possible to expose existing weaknesses that may otherwise go unnoticed. This also increases the risk of exploitation.

Guernsey's principles-based framework is intentionally designed to adapt to technological developments without inhibiting innovation. The GFSC does not intend to place additional burdens on firms. Under the existing framework firms have a responsibility to review and maintain their systems on an ongoing basis. Due to rapid technological development weaknesses must be rectified in a much shorter timeframe. In an outsourcing context, firms should ensure that third party providers meet these standards.

Read the GFSC's letter: GFSC issues Dear CEO letter on technology risk — GFSC

New Crown Dependencies authorised push payment (APP) framework

The GFSC is working with the Isle of Man Financial Services Authority and the JFSC to develop common principles to deal with APP fraud in the Crown Dependencies while recognising jurisdictional differences where appropriate. The framework focuses on on retail-customer banking activity and sterling payments over Faster Payments and CHAPS (Clearing House Automated Payment System) payments.

Banks are encouraged to consult the framework: Crown Dependencies APP Fraud Framework.pdf