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Addressing five big questions


01 Oct 2025

Andrew Hutchings talks to the Guernsey Financial Services Commission, Joe Moynihan of Jersey Finance, and the Isle of Man Financial Services Authority — covering geopolitics, regulation, digital assets, AI, and talent

Image: chris2766/stock.adobe.com
Comments of the Guernsey Financial Services Commission (GFSC), Joe Moynihan, CEO of Jersey Finance (JM), and the Isle of Man Financial Services Authority (IOMFSA).

Under the second Trump administration, the government of the US has moved decisively away from the post-1945 system of free trade and multi-lateral institutions. What threats and opportunities does this pose for your centre?

GFSC:
As a micro-state and a leading international finance centre, the Bailiwick of Guernsey has long operated in accordance with relevant international standards set by the International Organisation of Securities Commissions (IOSCO), the International Association of Insurance Supervisors (IAIS), the Group of International Finance Centre Supervisors, the Financial Action Task Force (FATF), and others. Our adherence to their standards has given others confidence in Guernsey as a reliable international financial centre that contributes to the highest standards globally. Meanwhile, the approach of the Trump administration, as well as Mario Draghi’s report on the competitiveness of the European Union, means that the global regulatory landscape may evolve in some unexpected ways.

The US shift perhaps provides room for some international simplification — hopefully preserving the benefits of some proven international standards, while perhaps reducing the bureaucracy associated with others. Guernsey will continue to contribute to the development of international standards and will always argue the case for sensible unbureaucratic norms: these should help create conditions that are likely to facilitate economic growth in the real world. Any debate — between those who champion regulatory caution and those who advocate economic growth and the fighting of poverty — should be a healthy one.

Moynihan: Our strategy vis-à-vis the US is focused on providing a platform for American fund managers to access European institutional capital, in a way that is both cost-effective and compliant with the latest regulations. We have seen good success from that strategy in recent years. Our time zone, common language, and similar work culture make Jersey a natural partner. In fact, since we established a presence in the US in 2019, the number of funds and sub-funds from that country are up 113 per cent. In parallel with this, we have also seen significant growth in corporate structuring, launching of securitised vehicles and intergroup funding.

We think that that trend will persist. It is probably a bit early to say what the long-term impact of recent political changes in the US might have on Jersey’s funds sector: nevertheless, it is clear that the fundamental reasons US managers choose Jersey remain strong. The structures we offer help them serve a global client base in a compliant and efficient manner.

IOMFSA: The Isle of Man’s chief minister, Alfred Cannan MHK, recently said that the rise in global trade tariffs is unlikely to have a substantial impact on the Island’s economy, due to our strong focus on services rather than goods.

Here at the IOMFSA, we continue to engage with firms to assess the threats and opportunities arising from any market volatility caused by current geopolitical issues. Trust and corporate service providers have reported limited immediate impact resulting from the US proposals — and typically are still forecasting growth without seeing any client attrition. However, there is potential for revenue to be impacted if there is a slowdown or pause in transactions due to the uncertainty in the markets.

Investment businesses are telling us that their managed portfolios are generally well diversified. While equity markets have fallen, bond markets have held up well as there has been a flight to quality. Exposures to alternative asset classes have also performed reasonably well. Indications are that investment businesses will continue to see a steady flow of new business.

In terms of economic opportunities, we are seeking to enhance the attractiveness of the Isle of Man’s captive insurance sector by introducing measures aimed at simplifying solvency capital requirement and introducing a fast-track authorisations process to improve the speed to market. We are also encouraging fintech start-ups to come to the Isle of Man by offering pathways for tech-based and AI solutions. The Fintech Innovation Hub provides a seamless entry point for new enquiries, as well as an ecosystem that can support fintech products and services from initial concept to market launch.

Over the coming year or so, what are the major changes — regulatory and other — that we should look out for in relation to asset servicing in your centre?

GFSC: Our focus is on innovation, simplification, and ease of use. In the funds sector, for example, we have already amended our Explanatory Note on fund authorisation and registration surrender, to reduce unnecessary regulatory burdens on funds and fund investors.

We have also launched a new applications and authorisations portal. This enables those wishing to undertake financial services business in Guernsey to apply and, on approval, have their license or registration issued through one secure, online portal.

The portal went live in April 2025 with a number of applications available. We will be enhancing the portal with more applications coming online during the year.

Moynihan: The interconnected nature of the private wealth, funds, and capital markets will become a more persistent theme for our funds sector in the coming months. We have done a lot of work around the notion that asset raising is no longer as straightforward as it once was, with managers facing more challenging conditions than they are accustomed to. This has prompted managers to diversify away from their traditional investor base and look to family offices and the broader high-net worth market, which remain under-allocated to managed funds.

Given the make-up of Jersey’s financial services landscape, which includes funds as well as private wealth, corporate and banking, there are big opportunities here. Jersey’s strength is its ability to adapt to that trend and deliver its expertise in a way that can support asset managers as well as private and institutional investors.

Meanwhile, sustainable finance is becoming increasingly important and embedded within our proposition as an international finance centre (IFC). A few years ago, we set out to define a clear vision for supporting sustainable finance. That means equipping financial services providers in Jersey with the knowledge and resources they need, so they can advise their clients on ESG and other sustainability issues.

We are continuing to build on that. Earlier this year, for instance, we held our first ever Sustainable Finance Summit. In addition, we are continuing to work closely with the government of Jersey on its Sustainable Finance Action Plan, which it published towards the end of last year. We want to make sure that Jersey not only follows international developments in sustainability but leads the way in supporting responsible finance and championing the importance of the UN’s Sustainable Development Goals (SDGs).

IOMFSA: We are moving forward with proposals aimed at enhancing the Isle of Man’s regulatory environment. The intention is to update existing legislation to ensure that the Isle of Man safeguards its reputation as a well-regulated jurisdiction that continues to meet international standards.

Amendments set out in the Financial Services (Miscellaneous Provisions) Bill will strengthen the IOMFSA’s ability to achieve its objectives of protecting consumers, reducing financial crime, and maintaining confidence in the finance sector through effective regulation.

The draft Bill includes plans to revise measures within the:

- Collective Investment Schemes Act 2008

- Designated Businesses (Registration and Oversight) Act 2015

- Financial Services Act 2008

- Insurance Act 2008

We are also currently assessing feedback submitted in response to a consultation on the Retirement Benefits Schemes (Amendment) Bill.

Modernising aspects of the current pension legislation is intended to help us remain effective and proportionate in the delivery of our remit.

The biggest challenge facing all sectors of the Isle of Man’s economy, not just asset servicing, is the jurisdiction’s next evaluation by MONEYVAL, the Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism.

Preparations for the onsite assessment in October 2026 are already well advanced across multiple government agencies.

The objective is to demonstrate that the Isle of Man complies with international standards and remains well placed to attract quality new business and investment.

The outcome of the MONEYVAL mutual evaluation report (MER) will be crucial to the Isle of Man’s continued economic success and its reputation as a well-regulated international finance centre.

MONEYVAL, which is the regional body of the Financial Action Task Force (FATF), assessed the Island’s legislation, policies and procedures during its last onsite visit in 2016. The 2016 MER provided a comprehensive assessment of how well the Isle of Man had implemented the international requirements, and highlighted areas where further enhancements were required.

A significant amount of progress has been achieved since the 2016 evaluation, with the Isle of Man positively marked in 39 out of the 40 FATF recommendations: this places us among a select group of nations in the world for technical compliance in AML/CFT.

An updated National Risk Assessment will be published later this year alongside a documented Risk Appetite Statement for the Isle of Man.

Data gathering and analysis is being enhanced as part of these initiatives to support the Island’s commitment to combating money laundering, the financing of terrorism, and the financing of proliferation of weapons of mass destruction.

What is your organisation’s approach to digital assets?

GFSC:
We are open to innovation and are committed to creating an environment where good business can grow. We see that the crypto- and stablecoin sector has been evolving fast, with some crypto currencies, such as bitcoin, reaching a kind of maturity.

As overseers of a long-established funds centre, we consider that collective investment schemes can, when appropriately run, provide vehicles for a range of investors to invest indirectly in crypto currencies. This is provided that the fund investor is well informed of the risks and is able to bear any potential losses. We are working on making sure that Guernsey’s regulations are appropriate for a world which is likely to see increasing asset tokenisation.

Moynihan: Jersey has been something of a trailblazer in the digital assets space: it was home to the first ever bitcoin hedge fund, for instance, more than a decade ago. We have continued to refine and enhance our regulatory environment for digital assets since then, in a dynamic but proportionate and responsible way, in areas like tokenisation. We are open to good-quality operators in these new areas, but we are also careful to maintain Jersey’s reputation as a safe, well-regulated jurisdiction. The Jersey Financial Services Commission (JFSC) published updated guidance on real world assets and initial coin offerings (ICOs) last year, which was a welcome step forward, providing further clarity.

It is important because we absolutely recognise that blockchain technology, AI, and tokenisation are transforming the market. The application of tokenisation is set to revolutionise access to alternatives, for instance, helping to break down existing barriers for private and family office investors. Tokenisation gives them improved liquidity, transparency, and control over their allocations, but without the extra fees. The fact that McKinsey estimates that total global tokenised market capitalisation is forecast to reach around US$2 trillion by 2030 is significant. Domiciles like Jersey can provide the sort of certainty managers need. Of course, that certainty is balanced with a progressive outlook, a respected regulatory regime, and experience in supporting tokenisation and virtual assets.

IOMFSA: In the Isle of Man, virtual asset service providers (VASPs) are covered by Schedule 4 to the Proceeds of Crime Act 2008 and are therefore subject to the Island’s AML/CFT/CFP Framework including the AML/CFT Code. VASPs are supervised for AML/CFT/CFP compliance by the Authority by virtue of being a designated business on the Isle of Man.

In the Isle of Man, a ‘virtual asset’ refers to a digital representation of value that can be digitally traded or transferred and can be used for payment or investment purposes. Virtual assets do not include digital representation of fiat currencies, securities, and other financial assets.

VASP means any natural or legal person who by way of business conducts one or more of the following activities or operations for or on behalf of another natural or legal person:

- exchange between virtual assets and fiat currencies

- exchange between one or more forms of virtual assets

- transfer of virtual assets

- safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets

- participation in and provision of financial services related to an issuer’s offer and/or sale of a virtual asset.

We continue to monitor developments in the global business community, particularly in respect of crypto and digital assets. We have issued a Call for Input and a discussion paper in recent times to invite feedback about the possibility of expanding the Isle of Man’s regulatory perimeter in the future to include certain crypto-related activities.

Our stance is to continue with our current approach and maintain a watching brief, while remaining conscious that any future regulatory changes in this area may need to be aligned with the frameworks in other key jurisdictions, such as the UK.

Does the rise of AI have implications for your centre?

GFSC:
The development of technology such as our new applications and authorisation portal demonstrates our commitment to efficiency.

To ensure that the commission is well-equipped to take advantage of the revolution in AI and associated technologies, we have set up two technology focused departments. The first is a Technology Supervision Unit to ensure we understand appropriately the newer technologies and cyber defences employed by the firms we regulate, The other is a Technology Innovation Unit to ensure we are developing and using newer technologies such as AI to maximise efficiency.

Moynihan: Fintech and the adoption of AI is a huge area of focus for Jersey. We have partnered with Digital Jersey, which is the Island’s dedicated technology agency, to make sure we are supporting innovation in every way possible. Jersey has an outstanding digital infrastructure. We were the first jurisdiction to roll out fibre optic connectivity to every home and business. That has given us some of the fastest internet speeds in the world, which really supports our modern financial ecosystem.

When it comes to fintech itself, we see both large institutions and smaller, homegrown firms exploring everything from automation to digital assets. For the multinationals, much of their technology is rolled out from head office. But for smaller players, there’s a lot of opportunity to innovate locally. Our role at Jersey Finance is to make sure the industry understands the potential of AI and fintech more widely, and has the support to develop new solutions.

IOMFSA: The Isle of Man’s regulatory framework is technology neutral, so firms remain responsible for the use of any technological solution, including AI, in carrying out regulated activities and are expected to put in place the appropriate risk management as part of their corporate governance.

In a wider context, like all forward-looking jurisdictions, the Isle of Man recognises that AI is a powerful driver of change across the global economy. AI presents a significant opportunity to enhance productivity across sectors — enabling businesses to streamline operations, optimise decision-making, and embrace these technologies to support sustainable growth and innovation.

In 2024, Digital Isle of Man, an executive agency of the Isle of Man Department for Enterprise, launched the ‘Activate AI’ programme, which aims to harness the benefits of AI while ensuring its responsible use by providing free training in AI technology, tools, and use cases for Island residents and businesses.

This initiative has already trained a significant number of individuals across the Isle of Man, and has begun to offer resources and assistance to companies exploring AI. Digital Isle of Man continues to build on this work to maximise the economic potential of AI in terms of productivity and efficiency.

Are there human resources constraints on the further development of your centre as a locale for asset servicing?

GFSC:
Guernsey has a large pool of skilled financial services professionals who are continually working to improve their skill levels across a range of financial services businesses. In this, they are assisted by the GTA University Centre which was set up nearly 30 years ago to help financial services professionals achieve their potential.

Moynihan: The competition for talent is real and is felt across all jurisdictions and geographies — driven by shifts in technologies and the greater demand for specialist cross-border expertise. We have been ahead of the curve and have in place a number of measures to help ensure that Jersey can maintain and grow a sustainable, highly-skilled workforce that is fit for the future. Doing so is imperative to our future competitiveness and resilience as an international financial centre.

As part of these efforts, Jersey Finance recently became a partner member of the Financial Services Skills Commission, an independent, not for profit, member-led body, representing the UK’s financial services sector on skills.

As a partner member, we’ll join the commission’s advisory group and actively participate in working groups to help shape strategies that promote reskilling, encourage continuous learning and upskilling, and support efforts to attract new talent. It is a reflection of our ongoing commitment to building a highly skilled, future-ready workforce for Jersey’s financial and related-professional services.

IOMFSA: The Isle of Man is home to a highly skilled and experienced workforce in the financial services sector, built up over many years. This foundation continues to support the sector’s development.

However, like our peers in many jurisdictions, we are mindful of the ongoing need to attract, retain, and develop talent in an increasingly competitive global landscape. By continuing to invest in skills, education, and technology — including through the adoption of AI — we can enhance productivity and ensure the sector remains resilient and future-ready.

We are aware of the competitive recruitment environment in the Isle of Man and are partnering with University College Isle of Man (UCM) to support the delivery of training and education in business administration, compliance, and anti-money laundering.

We are aware that compliance and supervisory skills are currently much sought after in the Island. Our collaboration aims to help students gain the relevant qualifications they need to pursue a career in the finance sector.

The Isle of Man has launched a Financial Services Apprenticeship Programme to create clear pathways into the financial services sector for young people.

The two-and-a-half-year programme includes a mix of full-time employment, study at the UCM and the opportunity to take professional qualifications.
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