Trust Reform and UHNW Mobility Trends: 2026 Crown Dependencies Update
Ultra high net worth families are weighing rising political risk, mistrust of governments and the prospect of less friendly tax regimes in some of the world’s largest economies. As a result, questions of jurisdiction, mobility and asset protection are moving up the agenda.
How the Crown Dependencies Are Positioning Themselves
Jersey and Guernsey are positioning themselves as predictable, rules based centres in response. Proposed changes to Jersey’s trusts law, follow up work after strong MONEYVAL assessments and the opening up of Guernsey’s family PIF regime all point to an emphasis on clearer creditor rights, modernised beneficiary provisions and new structures for cross border families.
The Isle of Man is also seeking to underline its regulatory credentials under new leadership at the Financial Services Authority. Taken together, the three Crown Dependencies are trying to offer something many clients feel they now lack at home: consistency, legal clarity and a framework that can withstand sharper political swings elsewhere.
Jersey Update: Client Sentiment: UHNW Anxiety and Mobility Trends
These pressures are already influencing client conversations, as Steven Bowen of ZEDRA explains.
Political Pressure Points Affecting UHNW Families
Steven Bowen, ZEDRA’s Regional Head of Crown Dependencies, based in Jersey who has 35+ years of experience in the offshore financial services industry says, “There are a number of core themes which will be a focal point for Private Wealth in 2026. Firmly on the agenda would be the rising mistrust of governments in a number of highly developed and rapidly growing economies. Expropriation is a theme for a number of UHNWs who are concerned with fractious domestic politics and an anti-globalisation agenda.”
Bowen refers to a wider set of risks for the UHNW client, including sudden increases in wealth taxes, targeted levies on particular asset classes, restrictions on moving capital out of a country, forced disclosure rules that expose assets to political risk and retrospective tax changes that undermine long standing arrangements. One story that highlights this is Steel magnate Lakshmi Mittal with net worth estimated at $21.4 billion. Media reports indicate that Mittal has ended his UK tax residency, is now registered in Switzerland and is expected to spend more time in Dubai citing government tax changes as the UK grapples with a new Labour government.
Bowen continues, “Unsurprisingly, global mobility walks hand-in-hand here especially when coupled with the rise of unfriendly tax regimes and other jurisdictions that are hungry to capture a piece of these UHNW wealth. We are expecting to see these drivers producing a continuing rise in the flight of capital and people to safe harbours and friendly territories.”
These client level concerns are feeding directly into how the Channel Islands are shaping their trust law and regulatory frameworks.
Trust Reform and Regulatory Shifts in the Channel Islands
While Bowen highlights the political and tax pressures influencing ultra high net worth families, lawyers in the Channel Islands are focused on how the legal framework is adapting. For Vicky Olivier, Senior Associate at Baker and Partners, the central question in 2026 is how trust law and regulation in Jersey and Guernsey are evolving in response.
Vicky Olivier, Senior Associate, Baker & Partners and an Advocate of the High Court in South Africa and barrister in England and Wales offers her thoughts. “As we move into 2026, the Channel Islands private wealth sector will continue to be shaped by the interplay between legislative modernisation, international regulatory expectations and the increasingly sophisticated needs of cross-border families. Both Jersey and Guernsey are consolidating the momentum of the strong MONEYVAL outcomes by embedding heightened governance and AML expectations into day-to-day practice.”
Jersey’s Trust Law Developments for 2026
“The trust landscape in the Channel Islands is also set for potentially meaningful evolution in 2026 as Jersey’s proposed amendments to the Trusts (Jersey) Law 1984 move closer to enactment. The draft legislation, recently lodged for debate by the Minister for External Relations, signals a decisive shift in how the island will address issues that have challenged trustees and lenders in recent years.”
“One of the most notable developments is the proposal to clarify priority in insolvent trusts, confirming that a lender with security over trust assets will rank ahead of a trustee’s lien. At the same time, the reforms seek to modernise beneficiary rights by confirming that where a trust instrument provides powers to add future beneficiaries, this will prevent the existing beneficiaries from terminating or varying the trust, even unanimously, under traditional doctrines. These changes reflect a broader trend, namely that trust structures are becoming more bespoke, more sophisticated, and increasingly tested by multi-jurisdictional families and financiers.”
“Against this backdrop, 2026 is likely to be a year in which Channel Islands practitioners need to revisit trust documentation, especially financing and security arrangements, and consider how existing discretionary trusts may interact with new statutory priorities. It also offers a window to explore innovative structures, while remaining alert to regulatory and cross-jurisdictional developments, including potential legal reforms in the UK around digital-asset property rights.”
Highlighted individuals in the Citywealth Magic Circle Awards for Jersey, Channel Islands.
Emma Dantec, Standard Bank
Emma Roberts, Entrust
Vote for them here
Within this broader Channel Islands story, Guernsey is also adjusting how families can access regulated fund structures.
Guernsey Update: Family PIF Access and Licensing Reform
While Jersey’s reforms concentrate on trusts law and creditor priorities, Guernsey, says Euan Melrose. Director, Business Development at trust company, the Imperium Group “is making a more targeted change to how wealthy families can access regulated fund structures.”
John Scanlan, Partner, Bedell Cristin, Guernsey says in a recent missive, “In October 2025, the Guernsey Financial Services Commission introduced a limited investment licence that allows fiduciary firms to act as the designated administrator of a Family Private Investment Fund, a structure reserved for family members and related employees.”
As one example, the regime could be used by families with existing structures who want to place their own capital into a regulated Guernsey fund without their fiduciary provider needing a full investment licence.
Highlighted individuals in the Citywealth Magic Circle Awards for Guernsey
Rhona Humphreys, Imperium Group
Stuart Dowding, Opera
Vote for them here
Alongside developments in Jersey and Guernsey, the Isle of Man has its own story driven by regulatory leadership and key industry appointments.
Isle of Man Update: Regulatory Direction and Industry Leadership
The Isle of Man’s direction is being shaped by Bettina Roth, who became Chief Executive of the Financial Services Authority in 2021 after senior regulatory roles in Canada, the Cayman Islands and Abu Dhabi. Under her leadership the Authority has outlined priorities that include consumer protection, financial crime prevention and a risk based approach to supervision, with a particular focus on preparations for upcoming MONEYVAL assessment work. The aim is to support the Island’s long term regulatory stability and to keep it aligned with evolving international standards. Roth says her role is “to protect consumers, combat financial crime, and maintain confidence in the financial services sector through robust prudential supervision.”
Nedbank Private Wealth, Isle of Man, has announced Andrew Corlett OBE as Chair of its Board. Andrew served as Chairman and Managing Director of Cains, a leading legal and professional services group and recipient of the Queen’s Award for Excellence in International Trade. He had positions within the HSBC and Swire Groups. Andrew Corlett OBE said “It is an honour to take on the role at such a significant moment in the Nedbank Private Wealth’s journey.” Stuart Cummins, Chief Executive Officer of Nedbank Private Wealth “Andrew’s appointment as Chair reflects our commitment to continuity and the values that define Nedbank Private Wealth.”
Crown Dependencies Respond with Structural Change
The Crown Dependencies move into 2026 with a clear emphasis on stability at a time when many ultra high net worth families are reassessing their exposure to political and fiscal risk. Jersey’s trust law review, Guernsey’s adjustments to its Family PIF regime and the Isle of Man’s regulatory priorities all point to a common direction. Each jurisdiction is seeking to strengthen confidence through predictable rules, clearer legal frameworks and steady supervision. As pressures increase in larger economies, the consistency offered by these islands is becoming a more prominent factor in private wealth planning.
Key takeaways
- Ultra high net worth families are increasingly focused on political risk, mistrust of governments and the potential for less favourable tax regimes.
- Jersey is progressing trust law reform that clarifies creditor priority in insolvent trusts and modernises beneficiary rights.
- Guernsey is widening access to regulated structures through the Family Private Investment Fund regime and the new limited investment licence.
- The Isle of Man is emphasising regulatory stability under the leadership of the Financial Services Authority and its preparation for future MONEYVAL work.
- Across the Crown Dependencies, legal and regulatory change is intended to provide clearer frameworks and greater confidence for internationally mobile families.
Citywealth looks forward to welcoming advisors and managers to the Citywealth IFC Awards on the 28th January 2026.
The host is Rebecca Jones.
Rebecca Jones is a highly experienced broadcast journalist and accomplished host and moderator. Across her nearly 30 years at the BBC she held a number of national and international roles, including Chief News Presenter on BBC1, BBC2, BBC World and the BBC News Channel, and anchored coverage of some of the biggest national and international news stories of recent years.
Shortlisted for 2026 includes
Lawyer of the Year – Channel Islands & Isle of Man
• Agnieszka Bielanska, Lexstone Lawyers
• Alexa Saunders, Carey Olsen
• Angela Calnan, Collas Crill
• Gilly Kennedy-Smith, Mourant
• Katherine Neal, Harneys
• Matt Guthrie, Ogier
• Nancy Chien, Bedell Cristin
• Nick Marshall, Nicolle Marshall
• Rajah Abusrewil, Walkers
• Simon Lofthouse, Corbett Le Quesne
Trust Company of the Year – Jersey
• Equiom
• HIGHVERN
• HSBC Trustee (C.I.) Limited
• JTC Group
• Ocorian
• Suntera
Trustee of the Year – Channel Islands & Isle of Man
• Áine O’Reilly, Baccata
• Daniel Channing, Whitmill
• David Stearn, Affinity Private Wealth
• Ian Rumens, Ocorian
• Paul Douglas, Accuro
• Rhona Humphreys, Imperium Group
• Richard Joynt, HIGHVERN
• Siobhan Crick, Collas Crill
• Steve Sokić, Crestbridge
Trust Company of the Year – Isle of Man
• Charterhouse Lombard
• Equiom
• IQ-EQ
• JTC Group
• Suntera
• Trident Trust Company
Trust Company of the Year – Guernsey
• Albany Trustee Company
• Beauvoir Limited
• Imperium Trust Company Limited
• New Street Management
• Oak Group
• Praxis
• Summit Trust
Private Banker of the Year – Channel Islands & Isle of Man
• David Woodhead, Butterfield Bank
• Eduar Klein, UBP
• Emily Dawson, Investec
• Henry Baye, Standard Chartered
• Kathleen Crozier, Nedbank Private Wealth
• Lloyd Maxwell, RBC Wealth Management
Private Bank of the Year – Channel Islands & Isle of Man
• Butterfield Bank
• EFG Private Bank
• Investec
• Julius Baer
• Nedbank Private Wealth
• RBC Wealth Management
• UBP
Investment Management Company of the Year – Channel Islands & Isle of Man
• Barclays Private Bank
• Canaccord Wealth
• Julius Baer
• LGT Wealth Management
• Melville Douglas
• Rathbones Investment Management International
IFC of the Year
• Cayman
• Delaware
• Guernsey
• Isle of Man
• Jersey
• Monaco
• UAE
ZEDRA’s Citywealth Leaders List profile
Baker & Partners’ Citywealth Leaders List profile
Bedell Cristin’s Citywealth Leaders List profile
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