Jersey – CM PB

Country Manual Private Banking

Jersey

out of Bank’s Country of Establishment (Def, RS, BT & RT)

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The manual has been reviewed and updated. There have been a number of changes to the content:

There have been no major legislative changes affecting the Template, but:

There is extra wording explaining the application and contents of application of the Financial Services Advertising Order (FSAO), including wording on unsolicited advertisements;

There is extra wording explaining Jersey deposit advertising requirements;

There is extra wording on advertising in the negotiation and collecting supporting documentation sections;

For wire transfers the answer is now Grey zone YES – as we have incorporated a comment applying where no money services are provided in Jersey;

For advisory services provided onsite or by remote means into Jersey:For macroeconomic information the answers are still Grey zone/YES but comments have changed to “no investment advice” and “no solicitation of orders”;

For research material, providing generic and personalised recommendations lists, spot advice and ongoing advice provided to non-qualified clients, the answers are now Grey zone/YES with a new added comment – When dealing with a natural person in Jersey who has entered into the transaction as a member of the public additional conditions apply.

We have reviewed and confirmed the interpretation of where advice is provided to a person in Jersey and note that the view of the Jersey Financial Services Commission is that giving investment advice to persons in Jersey, whether from inside or outside Jersey will constitute the carrying on of investment business in or from within Jersey (as advice is deemed to be given at the point of receipt). In general. giving investment advice in relation a specific product or service, gives rise to an obligation to register under the Financial Services (Jersey) Law 1998 unless an overseas entity is able to rely on an exemption.

It should be noted that Jersey is in the process of introducing consumer credit legislation and this is likely to affect future versions of the template.

Non-material changes

Some content has been amended and/or slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately. In particular:

There are minor changes to the wording covering EAMs in the Third Party Section.

There is further wording on controls for access to a bank’s website in the Advertising Section;

BT Short Comparison

This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “JERSEY” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Geneva, July 21^th, 2025