Administrative Penalty $20,000.00 - MCNAMARA CORPORATE SERVICES LIMITED (2022-01-14)

Summary

This is an enforcement notice published by the BVI Financial Services Commission announcing an administrative penalty of $20,000.00 imposed on McNamara Corporate Services Limited, along with a warning letter, for multiple contraventions of AML/CFT related requirements. It is a public record of a concluded enforcement action rather than a rule imposing new ongoing obligations on the industry generally.

• Penalty grounds: Failure to carry out a risk assessment (section 12 of the AMLTF Code of Practice), failure to meet customer due diligence requirements (section 19(2)), and failure to test business relationships (section 31(B)).
• Warning letter grounds: Lack of an independent audit function (section 11(3A)); failure to meet general training requirements (sections 47(1) and 48(2) of the AMLTF Code of Practice, and regulations 16(1) and (2) of the Anti-Money Laundering Regulations, 2008); and failure to meet business continuity plan requirements (section 27 of the Regulatory Code, 2009).
• Matter reference: Matter ID ENF011422/001.

The notice does not impose new obligations on other regulated entities; it serves as a public disclosure of the sanction against this specific licensee for past compliance failures.

Applies to

Trust and Corporate Services Providers