Channel Islands funds update: October 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 second quarter of 2025.

The total net asset value (NAV) of Guernsey funds at the end of the quarter was £270.9 billion. Within this total, Guernsey closed-ended funds held £226.6 billion, with the total net asset value of the open-ended sector at £44.3 billion. Guernsey Green Funds held a total net asset value of £4.5 billion at the end of the quarter.

See the statistics in full: Investment Statistics Summary Second Quarter 2025 – GFSC.  

Jersey investment statistics

The Jersey Financial Services Commission (JFSC) has published its investment statistics for the second quarter of 2025.

By the end of the quarter, the value of total funds under investment management stood at £36.1 billion, the same as in the previous quarter.

The total net asset value of regulated funds under administration increased by £14.1 billion from £451.8 billion to £465.9 billion during Q2 2025.

The number of registered Jersey Private Funds increased to 754, having risen from 750 at the end of Q1.

Meanwhile, the number of regulated collective investment funds increased from 588 to 608 during the quarter. 

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

Note that following the Government of Jersey’s announcement at the Mid-Year Financial Services Update: Strengthening Jersey’s Competitiveness, the JFSC will transition from a quarterly to an annual reporting cycle for fund statistics.

This change is designed to: 

• reduce the administrative burden on industry participants

• enhance the quality and accuracy of data submissions 

No fund statistics will be collected in October for Q3 and the reporting date for the new annual cycle will be confirmed in due course.

Jersey developments

Government of Jersey's competitiveness programme

In connection with the Government of Jersey's financial services competitiveness programme (discussed in our Channel Islands Funds Update: July 2025), the following reforms have been made over the last quarter:

Jersey Private Fund enhancements

Further to a period of consultation with industry, updates to the Jersey Private Fund (JPF) regime took effect on 6 August 2025 through new legislation and a revised Jersey Private Fund Guide. The enhancements reinforce the JPF’s reputation as a streamlined and flexible solution for private fund structuring.

Key changes include the removal of the previous 50-investor limit, enabling unlimited offers and investors provided the fund meets the definition of a "private fund" by being offered to a restricted group of investors. The reforms also broaden the categories of professional investors who are eligible to participate in a JPF and introduce a 24-hour authorisation process for new JPFs.

For a detailed overview of the changes to the JPF regime, read our insight: Further enhancements announced to the JPF regime.

See more information on the JPF regime:

• A guide to Jersey Private Funds

• Jersey Private Funds for Singaporean real estate investment managers

Revisions to the Sound Business Practice Policy

During this quarter, the JFSC consulted on proposed revisions to the Sound Business Practice Policy (SBPP) to simplify and streamline its application. The SBPP is a framework for identifying and managing activities that pose reputational risks to the island.

The updated policy was jointly prepared by the Government of Jersey and the JFSC, drawing on feedback received through the Government of Jersey's Competitiveness Programme. The proposed changes include amendments to the policy wording to enhance clarity and accessibility, the removal of Table 1 and the modernisation of Table 2 to introduce a new category for activities involving FATF blacklisted and suspended members.

A revised version of the policy, together with updated application forms and processes, will be issued by the JFSC in due course. Guidance will also be published to assist applicants during the transitional period.

View the revised Sound Business Practice Policy.

Repeal of the Control of Borrowing Framework  

Between July and September 2025, the Department for the Economy consulted on proposals to repeal the Control of Borrowing (Jersey) Law 1947 and the Control of Borrowing (Jersey) Order 1958 (together, the COB Framework), with the intention of integrating its provisions into Jersey’s modern regulatory laws.

The proposals include:

• retirement of ongoing conditions on registrants imposed under the COB Framework, as the conditions will be addressed instead through Jersey’s modern regulatory regime

• targeted amendments to product laws to preserve the JFSC’s ability to refuse registration applications on reasonable grounds

• introduction of a new class of financial services business under the FS Law to enable proportionate oversight of fund products previously within the scope of the COB Framework

• use of existing powers under the FS Law to ensure appropriate supervision of certain digital products

• collaboration with the JFSC to simplify administrative decision-making in respect of registrations

The JFSC intends that entities holding COBO consents at the time of repeal will retain good standing without the need for further action by the entities.

The consultation period ended on 30 September 2025 and feedback is expected in due course.

View the Consultation Paper: Repeal of the control of borrowing framework 

Limited Partnerships Law amendments

In June 2025, the Minister for External Relations approved drafting instructions to amend the Limited Partnerships (Jersey) Law 1994 to allow for the creation of compartments within limited partnerships.

The proposed amendments aim to enhance Jersey's competitiveness as a jurisdiction for fund structuring, promoting simplicity and cost effectiveness.

Amendments to the Financial Services Law

Amendments to the Financial Services (Jersey) Law 1998 (the FS Law) were adopted by the States of Jersey in July 2025 to introduce a consumer credit regime on the island. The changes establish "consumer credit business" as a new category of financial services business. The new category covers activities such as credit broking, debt-related services and entering into, exercising rights under and advising on relevant agreements and arrangements.

In-scope entities will be subject to supervision by the JFSC and must comply with the FS Law and any applicable codes of practice.

Several exemptions are included to balance consumer protections with practical business considerations, ensuring an effective regulatory framework without being overly burdensome. These exemptions clarify that certain activities are not covered if they are not conducted "by way of business." Additional exemptions for credit broking and debt-related activities are expected through ministerial orders.

A 12-month transitional period is provided for in the amending law for the supervision of consumer credit business by the JFSC. Businesses who need to apply for relevant registration with the JFSC will have six months from enactment of the amending law, or by any later date specified by the JFSC, within which to do so.

Read the amending law: Financial Services (Jersey) Amendment Law 202-

AIF Code of Practice consultation

The JFSC published a consultation proposing changes to the Alternative Investment Funds (AIF) Code of Practice on 2 October 2025. These changes ensure Jersey is aligned with the European Union’s (EU) updated Alternative Investment Fund Managers Directive (EU AIFMD) II, so that Jersey maintains market access in the EU. The JFSC led a working group that included experts in the funds sector to review AIFMD II and consider the possible legislative and Code changes required.

The working group concluded that:

• the AIF Code requires updates to reflect EU AIFMD II

• no legislative changes are required

• the changes to the AIF Code should not materially impact Jersey as a third country

Consultation responses are due by 17:00 on 30 November 2025.

2026 fees consultation

The JFSC published a consultation on proposed fees for 2026 on 13 August 2025. The 2025 consultation took place earlier than 2024, following feedback from industry that earlier certainty of fees would be welcome to aid in forward planning.

A general fee increase of 2.5% was proposed, together with adjustments to how fees are organised. These changes involve introducing a single consolidated fee schedule that applies to both Registry and JFSC regulated entities, bringing fees for legal persons and similar arrangements into alignment, streamlining and making consistent charges for late submissions and changes in control, as well as updating the fee structure relating specifically to funds.  The consultation closed on 12 September and feedback from industry was positive save that concerns were raised around the proposed annual fee for Alternative Investment Funds (AIFs). Therefore, the JFSC will not be progressing that particular change.

The fee notice published with the feedback paper confirms the fees for 2026 and will take effect on 1 January 2026.

Financial crime examination findings

The JFSC has published its findings from financial crime examinations conducted by the financial crime examination unit between 2023 and 2024. The feedback paper aims to support supervised persons in assessing the effectiveness of their own systems and controls in preventing and detecting financial crime.

Feedback areas covered in the report include:

• business risk assessments and governance

• systems and controls, including compliance monitoring programmes

• the role of MLCOs and MLROs

• identification measures

• enhanced and simplified customer due diligence

• exemptions

• suspicious activity reports

The paper outlines a number of good practices relevant to fund entities. Among other best practices, it highlights the importance of clearly defined board responsibilities, documented board-level discussions and effective tracking of action points. Regarding MLCO and MLRO roles, the report recommends regular oversight meetings, thorough documentation of conflicts and ensuring board-level engagement. In relation to period reviews, the report outlines best practices such as aligning the frequency of periodic reviews with customer risk profiles, maintaining appropriate documentation and ensuring effective tracking of completion and follow-up actions.

To review the findings in full, read the feedback paper.

Sustainable finance consultation

As referred to in our Channel Islands Funds Update: July 2025, on 27 May 2025, the JFSC published a consultation on proposals regarding sustainable finance.

Following industry feedback, there was strong support for proposed Code enhancements in relation to business integrity risks (anti-greenwashing). Feedback also acknowledged that the Codes already placed a clear obligation on firms to manage risks, but there was a clear desire for greater understanding of our expectations on sustainability within the existing framework.

A sustainable finance guidance note, covering sustainability-related risks and business integrity risks, will be published in Q1 2026. Revised Code provisions on anti-greenwashing will follow a one-year transition period, with full implementation by Q1 2027.

To support this process and ensure the guidance meets the needs of the local finance industry, the JFSC will work with industry on its development before publication and the start of the transition period.

Registry Supervision: Q2 2025 feedback

The JFSC published the findings of its Q2 2025 Registry Supervision inspection programme in July 2025. The report highlights common areas of non-compliance identified during inspections and interviews, alongside practical guidance to support improved registry submissions.

The most frequent deficiencies included:

• inaccurate recording of joint ownership of shares

• outdated or incorrect information in statutory registers

• directors’ details not updated after changes in circumstances

• inadequate identification of executors where the beneficial owner is deceased

• failure to disclose individuals controlling a corporate trustee not regulated by the JFSC

• registry filings not submitted within the required 21-day period

The report also outlines good practice, including ensuring timely updates to associated party records within the 21-day timeframe, submitting separate filings for individuals associated with multiple companies and correctly recording joint ownership.

The JFSC feedback provides a reminder of the benefits of using the myParties feature within myRegistry to streamline filings where a person is associated with multiple companies.

Firms may wish to read the JFSC Q2 2025 Feedback Paper and consider their registry practices

Jersey Financial Services Commission – How to incorporate a company 

The JFSC has updated its company incorporation guidance to improve the process and simplify the JFSC website. The new pre-submission checklist is designed to support all customers through the incorporation process, offering practical advice and ensuring users are better prepared for submitting their applications.  

Interim guidance on Jersey's approach to Pillar Two

The Pillar Two regime applies from 1 January 2025 to multinational groups (MNEs) with annual turnover over €750 million in two of the past four years. Jersey entities or branches may face two new taxes: a 15% Income Inclusion Rule (IIR) on non-Jersey profits taxed below 15%, and a 15% Multinational Corporate Income Tax (MCIT) on Jersey profits for "in scope" MNEs. Revenue Jersey has issued interim guidance covering when trusts and partnerships are included, relevant accounting standards, and treatment of Incorporated and Protected Cell Companies, including their cells.

Updated AMLSP guidance published

The JFSC has updated its guide to anti-money laundering services provider application process to reflect that:

• trusts themselves are not required to be registered under the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008

• trustees are in scope and must continue to be registered where they are acting in or from within Jersey and conducting Schedule 2 activities as a business

The updated guide (effective 6 October 2025) is available here: Updated AMLSP application guidance.

Feedback on disclosable beneficial ownership information

The JFSC has published its feedback on a consultation paper circulated in May 2025 concerning disclosable beneficial ownership information (discussed in our Channel Islands Funds Update: July 2025). The proposals in the consultation paper aimed to strengthen Jersey’s existing framework for collecting beneficial ownership data, in line with international standards and evolving best practices, while balancing privacy concerns and supporting Jersey’s reputation as a trusted international finance centre.

 The JFSC responded to industry feedback on: (i) thresholds for beneficial ownership; (ii) categories of beneficial ownership and control; (iii) direct and indirect beneficial ownership and control; and (iv) timelines for implementation.

Guernsey developments

Following a successful MONEYVAL assessment, the GFSC turns its attention to digital innovation in the financial services sector and further enhancing the Guernsey Private Investment Fund (PIF) framework.

New guidance on Fid Law licensees acting as designated administrators of PIFs

The GFSC has introduced a new limited POI licence, specifically designed to make it easier for fiduciary firms to act as Designated Administrator for Family Private Investment Funds (Family PIFs). This measure follows May’s announcement of a streamlined PIF regime and underscores the Commission’s ongoing focus on reducing regulatory barriers and supporting innovation. Family PIFs are collective investment schemes that are private in nature, only available to family members or eligible employees (including those of a family office) and are not to be promoted to the general public.

Under the new regime, fiduciary firms that are already licensed under the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc (Bailiwick of Guernsey) Law, 2020 (the Fid Law) may now apply for a limited POI licence, allowing them to administer Family PIFs without being subject to the full requirements of the Protection of Investors (Bailiwick of Guernsey) Law, 2020, provided they do not undertake additional regulated investment activities.

Digital Finance Initiative

The GFSC has launched the Digital Finance Initiative (DFI) programme with the aim of ensuring that its financial services legislation is appropriately tuned to support innovations in digital finance.

To facilitate this work, the GFSC is setting up a Digital Forum as a platform for dialogue and collaboration. This forum will use roundtable sessions and workshops to gather insights from practitioners to inform the development of policy improvements on which the GFSC will then formally consult. Two roundtable sessions were held in September 2025 focusing on stablecoin infrastructure, exploring its potential role in financial markets, implications for regulation and opportunities for Guernsey to lead responsible innovation.

As part of the DFI, the GFSC is considering reducing licence application fees for virtual asset service providers (VASPs). The GFSC will also review opportunities to enhance the guidance within the Handbook, with a focus on supporting firms using technology effectively to combat financial crime efficiently.

Read more on the GFSC's Digital Finance Initiative. The GFSC is already rolling out a series of initiatives under the DFI, as summarised below.

Further incentives for VASPs

In our July 2025 update we analysed the GFSC's updated position on cryptocurrency funds.

As a further step in the same direction, the GFSC is proposing to introduce a material reduction to VASP fees, aiming to encourage the development of this emerging market as part of the DFI.

New Innovation Sandbox + Concierge

The GFSC has launched a new initiative, the Innovation Sandbox + Concierge, which aims to offer the opportunity for firms to navigate the regulatory landscape when launching innovative products and services which may pose new questions on existing regulatory categories (such as blockchain, tokenisation, AI-driven finance and similar). This new initiative aligns with the GFSC's approach to welcome early conversations to discuss licensing novel digital finance propositions.

The Sandbox allows firms to operate under tailored licence conditions, such as:

• scope limitations (capped transaction volumes or restricted client bases, for example)

• duration (12-24 months)

• disclosure (reporting of risks, incidents, and outcomes)

• consumer protection (use of disclaimers and opt-in participation)

Each applicant is assigned a named contact and guided through a bespoke pathway, starting with a Concierge Connect Form, based on which the GFSC conducts an initial review to determine how best to support the application and, if appropriate, culminating in an online application process via the GFSC's Applications and Authorisations Portal launched earlier this year.

The Concierge service, which is supported by Guernsey Finance, complements the above and aims to help Guernsey's financial service community make meaningful connections.

Read more about the GFSC's Innovation Sandbox + Concierge and the review phases.

New Engagement Hub

The GFSC has launched its new Engagement Hub which replaces the Consultation Hub previously. In addition to publishing consultations, discussion papers and providing feedback to industry on previous engagement activities, the site will also include details of upcoming events. The Engagement Hub can be accessed at engagementhub.gfsc.gg and via the GFSC's website.

Previous consultation papers, discussion papers and feedback papers are still available to view under the "Legislation and Guidance" section of the GFSC's website.

Digital Forum roundtables: Digital asset custody

As part of the DFI, the GFSC will host Digital Forum roundtable sessions on various digital finance topics with practitioners and stakeholders.

The GFSC will host its next Digital Forum roundtable at its offices at Regency Court at 14:00 on 22 October. It will focus on digital asset custody. The event is open to representatives of the Bailiwick’s financial services sector and other stakeholders with expertise or interest in this topic.

This session follows previous roundtables on asset tokenisation and stablecoins, during which digital asset custody arose as a relevant topic meriting its own discussion. The meeting will discuss the potential opportunity for digital asset custody activity in the Bailiwick, potential current impediments to this activity, the optimal regulatory landscape for digital asset custody and ancillary activity (custody of traditional securities underlying digital assets, for example).

Those interested in attending may register for a place via the GFSC's Engagement Hub.

Successful release of GFSC Applications and Authorisations Portal

The GFSC has confirmed that release of the new Applications and Authorisations Portal (A&A Portal) was completed on 8 August 2025, three months after its beta launch.

Applications to the GFSC are now submitted via the A&A Portal with the aim of ensuring consistent quality and completeness of submissions. The A&A Portal is designed to support online collaboration and communication, both prior to submission between parties drafting an application, and with the GFSC following submission.

Acting as a director of an entity with an established place of business in the Bailiwick of Guernsey: what this means according to the GFSC

The GFSC has clarified the factors which should be taken into account when considering whether a company has an "established place of business" in the Bailiwick for the purposes of the Fid Law.

Acting as a director in or from within the Bailiwick of any company or unincorporated body whether incorporated, registered or established in or under the laws of the Bailiwick or elsewhere by way of business is a regulated activity under the Fid Law. In this regard:

• "by way of business" is defined under the Fid Law as

•  "in or from within the Bailiwick" includes in or from within Guernsey, Alderney and Sark. Therefore if a director does not live in the Bailiwick then the directorship activity will fall outside the scope of the Fid Law.

If an individual is carrying on director activity by way of business in or from within the Bailiwick then this activity will fall into one of four categories:

• activity exempt from licensing and registration

• activity exempt from licensing and registration but subject to AML / CFT / CPF obligation

• activity exempt from licensing but requiring to be registered and subject to AML / CFT / CPF obligations

• activity requiring a Personal Fiduciary Licence

The GFSC has published detailed guidance in respect of each of the above categories.

In conjunction with the above, the GFSC has issued a clarificatory statement regarding the exemption under section 3(1)(b) of the Fid Law for acting as a director of a company with an established place of business in the Bailiwick provided that no services consisting of, or comprising a regulated activity, are supplied to the company by the director (which falls into the first of the above categories).

In essence, this exemption is not intended for use by directors of companies which have no clear substantive business activities being carried out in the Bailiwick. In particular, the GFSC has specified that merely having a registered office or holding statutory documents in Guernsey sufficient to meet requirements under the Companies (Guernsey) Law, 2008 or the Companies (Alderney) Law, 1994 does not amount to an established place of business. Factors to be considered to determine whether an entity has an established place of business in the Bailiwick include, by way of example, whether the it has premises and staff of its own in the Bailiwick, the nature of its occupancy of its Bailiwick premises, what activities or services it carries out within the Bailiwick.

Thematic reviews on conflicts of interest

The GFSC has published two thematic reports regarding conflicts of interest in the investment and fiduciary sectors, respectively. Included at Appendix A of each report is a non-exhaustive list of the types of conflicts of interest reported by licensees.

In relation to its review in the investment sector, key findings include:

• licensees reported a wide variety of types of conflicts of interest which they have encountered or may encounter, which reflects the high risk of conflicts of interest in this sector due to the nature of client relationships and services provided to those clients

• in general, firms take appropriate steps to identify and manage conflicts of interest that arise during the course of doing business, however the GFSC noted that some licensees appeared to be overly focused on conflicts involving the board of directors and encourages firms to consider conflicts that exist throughout the business

• licensees generally recorded conflicts of interests that had already arisen or may arise in an appropriately detailed conflicts register, however not all licensees appropriately recorded the specific controls implemented to manage such conflict

• licensees generally have policies that are proportionate to the nature, scale and complexity of their businesses, including through periodic training and specific tests within their compliance monitoring programme to monitor the effectiveness of their control framework for conflicts of interest

The GFSC encourages all firms to consider the contents of the reports, particularly in relation to the areas to consider and the appendix which lists types of conflicts to consider when reviewing, updating or revising policies, procedures and controls.

Feedback paper on sustainability reporting and consultation on anti-greenwashing guidance

The GFSC has published a feedback paper regarding the responses received to its discussion paper on the Future of Sustainability Reporting in the Bailiwick of Guernsey issued on 30 July 2024. The discussion paper sought to gather information and views from the finance sector on the potential impact of the introduction of the standards that have been issued by the International Sustainability Standards Board (ISSB). Both the discussion paper and feedback paper are published on the Engagement Hub.

Key aspects identified in responses were the importance of interoperability and flexibility in disclosure requirements and a common concern was the need to avoid conflicts with existing international disclosure requirements, such as any which are applicable through parent groups, listing venues, markets and so on.

The GFSC notes that the majority of respondents expressed support for a proportionate approach to adopting the ISSB reporting, aligning with international peers. Therefore, the GFSC has confirmed that, whilst supervised entities are allowed to make disclosures in compliance with ISSB standards on a voluntary basis, there are no plans to implement mandatory sustainability disclosure schedules in the foreseeable future.

Based on the feedback received, the GFSC proposes a small amendment to the Financial Sector Code of Corporate Governance to highlight the importance of considering environmental risks rather than only climate change risks, taking into account the global Convention on Biological Diversity. The GFSC also proposes to issue anti-greenwashing guidance clarifying that greenwashing is already forbidden under the Minimum Criteria for Licensing. The proposed text of this guidance is set out under Schedule 1 to the feedback paper.

The consultations undertaken in respect of the above proposals closed on 26 September 2025.

Updated Enforcement Explanatory Notes

The GFSC has revised the following documents relating to enforcement processes:

• Explanatory Note on the Investigation and Decision-Making Process in Relation to the Use of Enforcement Powers under the Financial Services Business (Enforcement Powers) (Bailiwick of Guernsey) Law, 2020

• Explanatory Note on the GFSC's General Approach to Enforcement and Enforcement Measures, which aims to consolidate all explanatory notes relating to the GFSC's enforcement powers into one reference document

As a result, all matters going forward will be dealt with in accordance with the new processes set out in the above explanatory notes.

It is worth noting that the above explanatory notes do not hold the force of law, therefore the GFSC has the power to examine each case on its own merits and in accordance with the applicable laws.

Updates to the AML / CFT / CPF Handbook

On 4 September 2025 the GFSC published an amendment to Appendix C 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 include Malta in the list of equivalent jurisdictions.

Appendix C of the Handbook lists those countries or territories which require businesses to have in place measures consistent with the FATF recommendations and where such businesses are appropriately supervised for compliance with such requirements. It is worth noting that the inclusion under Appendix C does not signify that it is intrinsically low risk.

In practice, the inclusion of a jurisdiction in Appendix C means that that in certain circumstances specified in the Handbook, firms opt to may apply specific customer due diligence (CDD) concessions to businesses connected with the jurisdiction only where the risk is assessed by the firm to be low. In determining the risk, the customer risk assessments must consider all relevant risk factors and not solely by reference to the jurisdiction’s inclusion on Appendix C.

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

Updates to sanctions framework

With effect from 5 August 2025, the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Amendment – Global Irregular Migration etc) Regulations, 2025 amend the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations, 2020 in order to give effect within the Bailiwick of Guernsey to the Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025 which were introduced in the United Kingdom.

GFSC consultation on fees for 2026

The GFSC has undertaken a consultation in relation to the proposal for an overall increase of 3.9% in fees paid by regulated entities, in line with the rate of inflation in Guernsey as of 30 June 2025.

Other important proposals outlined in the consultation paper include:

• rebasing of PIF fees to enhance the Bailiwick’s competitive position in the funds sector, with a change to the structure of fees for banded investment licensees consequent adjustments for designated administrators

• adjustment to the banded fiduciary fees in recognition of, and in response to, the growing disparity between firms at the top and bottom of the higher bandings as a result of recent mergers and acquisitions

• introduction of banded fees, rather than a per employee fee, for prescribed businesses to make the costs simpler and fairer for businesses with fewer staff

• introduction of fees, based on a “user pays” principle, to reflect the additional work and due diligence needed when positive approval is required for the following requests:

  • change of designated custodian or designated administrator of a fund

  • transfer of business between investment or fiduciary licensees

  • change of general representative for insurance firms

  • additional fund elements being added to a closed-ended investment fund

• linked to the above is the introduction of an annual fee in respect of individual elements or share classes of closed-ended funds, mirroring the fee applicable for open-ended funds

• material reduction to VASP fees, aiming to encourage the development of this emerging market as part of the DFI

• introduction of application and annual fees for firms wishing to undertake activities under the new equity release framework

Changes to GFSC senior leadership roles

The GFSC has reported a number of promotions and changes to its senior leadership roles.

With effect from January 2026, Dr Jeremy Quick will move from being Director of Banking and Insurance to being the part-time Director of Resolution and will work to ensure a proper and economical implementation of the Bank Resolution (Bailiwick of Guernsey) Law, 2025 over the next three years.

Martin McHugh is promoted to Director of Banking and Insurance Supervision following previous roles at the GFSC where he has led on policy development across the banking, insurance, fiduciary, investment and pensions sectors at different times.

Nick Herquin is promoted to Director of Investment, Fiduciary and Pension Supervision and will continue to undertake MONEYVAL / FATF inspection work to ensure that the GFSC remains abreast of evolving international expectations.

Gillian Browning, Deputy Director General (Policy and Supervision), will, inter alia, lead the GFSC’s policy development programme, including the new policies being co-developed with both industry and the legal community under the Digital Finance Initiative. In this work she will be supported by Jon Tooley and Lisa Peterson, who also remains the GFSC’s Chief Actuary.

Dr Conor Osborough is promoted to Director of Technology. In his new role, he will champion the GFSC’s internal optimisation of technology to increase efficiency and effectiveness.

Alice Joy, the GFSC Secretary, has had her title amended to Director of External Affairs and, in addition to her current responsibilities, will also be absorbing Nick Herquin’s current duties as Head of International Co-operation and Economic Enhancement.