ISLE OF MAN: FSA STRESSES NEED FOR TCSP TO UNDERSTAND UNDERLYING ACTIVITIES OF CLIENT AS CIVIL PENALTY IMPOSED

On 21st November, the Financial Services Authority published a public statement about a civil penalty issued against Fedelta Trust Ltd for £73,644 (discounted by 30% to £51,551 due to co-operation by the company).  In the key learning points identified for business, the FSA states that s regulated entity’s risk management arrangements, including in respect of AML/CFT, should extend to understanding of the investment and operational activities of its clients – even when the regulated entity is, as a registered agent, providing only limited services to its clients.  Not all clients have the same characteristics; and the risks associated with a particular client may not be mitigated by simply applying ‘standard’ processes and procedures.

https://www.iomfsa.im/fsa-news/2019/nov/public-statement-concerning-the-imposition-of-a-discretionary-civil-penalty-under-section-16-of-the-financial-services-act-2008/

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at https://www.buymeacoffee.com/KoIvM842y

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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