Basic Search  |  Summaries  |  Advanced SearchPenalty: £295,221
Year: 2022
Date: 5 August, 2022
Offence Group: financial offences
Offence Type: anti-money-laundering deficiencies
Violation Description: The Authority conducted the Investigation and was, at all times, mindful of the higher risk profile of the Trident IOM customer base. Licenceholders with such a profile and, in the case of Trident IOM a historically higher risk appetite, are naturally required to be able to demonstrate the highest standards of governance, risk and compliance frameworks and a culture that pervades high ethical and moral standards to the conduct of business and compliance with the regulatory framework. Similarly to the work of the Consultants and the work of the professional appointee under sections 14 and 23 of the Act, the Investigation identified a range of material weaknesses at all levels of Trident IOM's control and governance structure during the material times that, on reasonable grounds, brought into question Trident IOM's fitness and propriety. This included failures by Trident IOM to organise and control its affairs in a responsible manner; deficient systemic anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”) policies and procedures; and conduct of business failings in respect of entities administered by Trident IOM. Amongst the matters confirmed were that Trident IOM: had not been fully meeting a number of Code requirements - Trident IOM was contravening certain aspects of paragraphs 4, 5, 6, 8, 12, 13, 14, 15, and 30 of the Code; had not been fully meeting Rule Book requirements in relation to maintaining appropriate internal and operational controls, systems, policies and procedures - Trident IOM was breaching certain aspects of rules 8.2, 8.3, 8.9, 8.10 and 8.62 of the Rule Book; and had not been fully meeting rules relating to the conduct of business under the Rule Book – Trident IOM was breaching certain aspects of rules 6.1, 6.2 and 6.11. The matters detailed are serious and if not adequately addressed, particularly in terms of the preventative measures set out in the Code, significantly increase the risk that Trident IOM's services could have been exploited by persons who may wish to launder money or finance terrorism and therefore, by association, may have negatively impacted upon the Authority's regulatory objectives and the reputation of the Isle of Man as a responsible and well-regulated International Financial Centre.
Agency: Isle of Man Financial Services Authority
Source of Data: (click here)