Civil Penalties - Conyers Corporate Services Limited (2022-05-02)

Summary

This is a press release from the Bermuda Monetary Authority announcing civil penalties totalling $981,000 against Conyers Corporate Services (Bermuda) Limited, a corporate service provider licensed under the Corporate Service Provider Business Act 2012 (CSPB Act). The penalties relate to historic compliance failures identified during 2018 on site inspections covering AML/ATF and prudential matters.

• AML regulatory failings: Inadequate compliance with the Proceeds of Crime (Anti-Money Laundering & Anti-Terrorist Financing) Regulations 2008, including Customer Due Diligence, Ongoing Monitoring/Periodic Review, Enhanced Due Diligence, Systems, Training, and Compliance Officer requirements.
• CSPB Act failings: Deficiencies in meeting the Minimum Criteria for Licensing under the CSPB Act, specifically Corporate Governance Policy, conducting business in a prudent manner, and notification of change of controller.
• Remediation history: The Authority required deficiencies to be rectified by December 2019; the Company made considerable progress but some issues were not fully remediated by that date, though it later complied with the Authority's directions.
• Mitigating factors considered: Penalty level reflected factors such as the size and quality of the Company's book of business, absence of financial benefit from the breaches, full cooperation, ongoing remediation commitment, offers of regular compliance updates, and significant remediation costs incurred.

The notice is purely informational, describing an enforcement outcome already concluded; it does not itself impose new ongoing obligations on the Company or other licensees, though it underscores the Authority's expectation that Corporate Service Providers maintain up to date, effective AML/ATF policies and procedures.

Applies to

Corporate Service Providers licensed under the Corporate Service Provider Business Act 2012