Helen Hatton

Helen Hatton



How to undertake effective enhanced due diligence – AML/CFT

Professional profile

Widely recognized as the prime architect of the modern Jersey regulatory regime, Helen Hatton retired as Deputy Director General of the Jersey Financial Services Commission in May 2009 having led the implementation of regulatory development in the island from its blacklisted state in 1999 to achieving one of the world’s best IMF evaluation results. Specific milestones during this appointment included the introduction and implementation of an all crimes money laundering regime, an investment business regulatory framework for those who advise, manage and deal in investments, the trust company business framework (a definition subsequently adopted in the 3rd Money Laundering Directive and FATF 40+9 Recommendations) and regimes for expert funds, money services businesses, fund functionaries and general insurance intermediary businesses and the policy development work relating to a depositor compensation scheme, ultimately enacted in 2011.

Mrs Hatton established Sator Regulatory Consulting (now part of BDO, the fifth largest global professional services firm since April 2016), which undertakes assignments for a range of
international standard setting bodies, governments, regulatory authorities and leading financial services businesses, including the World Bank, IMF and UK Foreign & Commonwealth Office. BDO Sator was appointed independent Reporting Professional by the BVI Financial Services Authority in respect of the Mossack Fonseca “Panama Papers” scandal. Mrs Hatton has been appointed Financial Sector Expert by the IMF on three occasions to lead international evaluations of jurisdictional AML/CFT standards (Ghana, Aruba and Austria) and is the Chairman of the Anguilla Financial Services Commission on appointment from the UK Foreign and Commonwealth Office. She is also a board member of the Ras al Khaimah International Commercial Centre (RAK is the UAE manufacturing emirate) and Chairman of its Strategy Committee.

Currently, trending assignment types relate to working with financial institutions to strengthen governance, improve board effectiveness, risk management and AML/CFT defences; compliance project resourcing and management; independent review of complaints; assessment and implementation of fintech/regtech solutions, independent compliance monitoring, and undertaking enhanced due diligence reports through BDO Sator’s sister company, KYC Worldwide Ltd.


Educated at Hurst Lodge, Sunningdale and St Wilfred’s, Exeter followed by Plymouth University, Mrs Hatton lectured in Business Studies in further and higher education institutions in the south west of England until joining American Express Bank where she advised private clients on wealth management solutions from 1989 to late 1991 and achieved the ranking of “Top Producer” three years running.

Mrs Hatton was appointed director of enforcement to the Isle of Man Financial Supervision Commission in 1992. Notable achievements during this period included the introduction of all crimes money laundering legislation, an investment business regime, handling the investigation and winding up of the IOM operations of BCCI and Barings, updating the IOM Depositor Compensation Scheme and successfully taking 52 cases to Court, one of which notably achieved the world’s first “freestanding” offshore Mareva injunction without a local cause of action in the case SIB-v-Lloyd Wright bringing an effective end to secrecy in the Crown Dependencies.

Mrs Hatton is a Fellow of the Institute of Advanced Legal Studies, a member of the Editorial Board of the Journal of Banking Regulation, and a Liveryman of the Worshipful Company of International Bankers. She is a recognised international speaker on regulatory and compliance topics and is Chairman of BDO in Jersey, whose activities cover Audit, Advisory, Tax, Business
Solutions and Outsourcing, and IT.