We are excited to announce the newly updated Jersey Private Fund (JPF) Guide, designed to further improve the JPF regime. This is the result of a joined-up approach between the Government of Jersey, the Jersey Financial Services Commission, the Jersey Funds Association, the Jersey Association of Trust Companies and Jersey Finance.

The JPF regime offers fund promoters a cost-effective, fast-track (48 hour) regulatory approval process for private funds. The streamlined approach allows up to 50 eligible investors to participate.

What’s new?

Carry and co-investment vehicles

It is recognised that co-investment can be integral to a fund’s carry or incentive arrangements, enhancing the flexibility of investment structures.

Investor eligibility

General: Eligibility is now clarified as being satisfied upon admission, maintaining validity even if there’s a change in status (e.g. a departing employee, director, partner, or expert consultant).

Transfers: In cases of involuntary interest transfer, such as death or bankruptcy, the transferee must meet the investor eligibility requirements, though not necessarily through the same criteria as the transferor.

Service providers: The ‘professional investor’ category has been expanded, replacing ‘senior employee’ with ‘financially sophisticated employee’ and including ‘expert consultant’ for greater inclusivity and flexibility.

Governing body

The regulator’s expectation is that at least one Jersey resident director should be appointed to a JPF board or its governing body. The 2024 JPF annual compliance return will collect data on the composition of these boards, including the number of Jersey resident directors and their affiliation with the Designated Service Provider (DSP).

Non-JPF arrangements

The guidelines for arrangements not classified as JPFs have been updated, including family and incentive arrangements like carry and co-investment vehicles. Definitions for employees and family connections have been broadened to encompass trusts established for individuals meeting the expanded definition of ‘family connection.’

Additional key changes

  • Money laundering and outsourcing: References to the Money Laundering (Jersey) Order 2008 and the JFSC’s Outsourcing Policy have been added.
  • DSP regulation: From July 2024, regulated persons registered solely for investment business under the Financial Services (Jersey) Law 1998 will no longer be able to apply as the DSP for a ‘very private’ JPF (with 15 or fewer offers/investors).

Explore the comprehensive changes in the consolidated redline version of the updated guide, ensuring you stay fully informed.

For more information, please visit the Jersey Financial Services Commission website.