Administrative Penalty $20,000.00 - PATTON, MORENO AND ASVAT (BVI) LIMITED (2015-04-09)

Summary

This is a published enforcement notice from the BVI Financial Services Commission recording an administrative penalty of $20,000.00 imposed on Patton, Moreno and Asvat (BVI) Limited. The penalty was for contraventions of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008, relating to customer due diligence failures.

• Enhanced due diligence: Failure to engage in proper enhanced customer due diligence, contrary to section 20(2) and (4) of the AML/CFT Code.
• Ongoing due diligence review: Failure to review and keep up to date customer due diligence information as required, contrary to section 21(1) and (2).
• Introducer oversight: Failure to adequately ensure that an introducer reviewed and maintained customer due diligence information as required, contrary to section 31(5).

The notice is historical and record-keeping in nature, documenting a completed enforcement action (Matter ID BF101113/265) rather than imposing any new ongoing requirement on other entities. It serves as a public alert of the Commission's enforcement activity.

Applies to

trust and corporate services providers, entities subject to the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008