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Violation Tracker UK Individual Case

Company: Kestrel Insurance Services Limited
Penalty: £57,927
Year: 2020
Date: 17 January, 2020
Offence Group: financial offences
Offence Type: anti-money-laundering deficiencies
Violation Description: Operation and oversight of its client money account in a manner contrary to Paragraph 4(i) of Schedule 3 to the IIIR. Policy premium refunds properly due to and payable to clients were not processed in a timely manner contrary to Paragraph 4(i) of Schedule 3 to the IIR. Policy premium refunds properly due and payable to clients were held in a non-client money account where, on occasions, the client could not readily be contacted. Such practice is contrary to the IIR. The filing of inaccurate annual registration declarations. Politically exposed persons not properly identified or risk assessed in contravention of paragraph 14 of the Anti-Money Laundering and Countering the Financing of Terrorism Code 2015 (“the Code”). By adopting the UK AML/CFT framework, Kestrel could not demonstrate that it had paid proper heed to the Isle of Man legislation on that subject in contravention of paragraph 31 of the Code. Failure to record proper business, customer and technological developments risk assessments in contravention of paragraphs 6, 7 and 8 respectively of the Code.
Agency: Isle of Man Financial Services Authority
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