Sachin Sahani Talks Building a Culture of Compliance in Jersey

Recently, Jersey’s compliance and financial services experts gathered for an in-depth panel discussion organised by Sqope Intelligence – focused on the theme of ‘Staying on the Right Side of Enforcement’.

Hosted at The Royal Yacht Hotel, panellists included JTC’s Sachin Sahani, Head of Compliance for Group PCS and Jersey, along with Tony Shiplee (Director – Mourant) and Barry Faudemer (Chief Executive – Baker Regulatory Services Limited).

The interactive session explored the crucial themes of enforcement, governance and AML lessons for firms operating in, and under the supervision of, the Jersey Financial Services Commission (JFSC).

In this article, Sachin shares his practical takeaways – essential advice for compliance officers, board directors and business owners committed to getting compliance right.

1. Good Governance Starts from the Top
Staying on the right side of enforcement isn’t just about avoiding mistakes – it’s about establishing the right culture from the top down. Enforcement rarely begins with a single catastrophic failure. Instead, it often follows accumulating shortcomings in governance, tolerance of weak controls and failing to address risks early. Where the board demonstrates strong oversight, open challenge and proactive correction, firms are far less likely to encounter regulatory enforcement.

2. The Board Must Record Challenge and Discussion
An effective board not only provides strategic direction – it actively challenges and scrutinises business decisions. Comprehensive board minutes and detailed records are vital. These prove, in hindsight, the board’s engagement and due diligence. Whether presenting to the board or contributing to board submissions, clarity and completeness are crucial.

3. Controls: Business Risk Assessments as Live Documents
A robust control environment is foundational and central to this is the Business Risk Assessment (BRA). It should not be a document created merely to satisfy the regulator. Instead, the BRA is a practical tool for understanding the firm’s risk profile and guiding day-to-day decisions. Frequent updates and genuine board-level engagement with the BRA make the process meaningful for both oversight and business operations.

4. Engaging the Business – Not Just the Compliance Team
For risk and compliance (R&C) functions to have real impact, they must build strong connections across the business. This means attending management meetings, raising awareness in practical ways and delivering interactive training tailored to the audience. Shifting from a tick-box mentality to a genuine partnership helps embed compliance into the culture of a firm.

5. Horizon Scanning: Staying Ahead of Change
Anticipating regulatory change – or what we call ‘horizon scanning’ – enables firms to remain agile and well prepared for new or evolving rules. Incorporating regular discussions about emerging risks and upcoming requirements helps prevent surprises and allows for smoother implementation of policy changes.

6. Tailoring Policies and Procedures for the Audience
Policies and procedures should not simply mirror regulatory handbooks. Rather, they should be written with the end-user in mind – making them accessible, practical and easy to understand for the business (not just R&C or the regulator). Clear language and actionable procedures drive better understanding and easier adoption.

The panel served as a timely reminder that staying on the right side of enforcement isn’t necessarily about doing something extraordinary. Instead, Sachin stresses that it’s about doing the ordinary extraordinarily well. Strong governance, active board engagement, effective controls, and a partnership approach between compliance and the business remain any firm’s best defence against enforcement risk.