Administrative Penalty $20,000.00 - Circle Investment Support Services (BVI) Ltd. (2016-02-23)

Summary

This is an enforcement notice published by the BVI Financial Services Commission announcing an administrative penalty of $20,000.00 imposed on Circle Investment Support Services (BVI) Ltd. for breaches of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008. It is a historical record of a completed enforcement action rather than a document imposing new ongoing rules.

• Section 12 breach: Failing to establish a written system of internal controls and to undertake money laundering and terrorist financing risk assessments for each customer, business relationship or one off transaction.
• Section 19(5) breach: Failing to carry out due diligence on a legal person and to collect identification information on the legal person and its underlying principals.
• Section 21(1),(2),(4) breach: Failing to review and keep up to date customer due diligence information in the manner required by the Code.

The notice records Matter ID BF101113/284 and serves as a public alert of the sanction taken; it does not itself create new prospective obligations for other entities beyond illustrating the AML/CFT compliance standards the Commission enforces.

Applies to

Circle Investment Support Services (BVI) Ltd.