Administrative Penalty $25,000.00 - Midland Trust Limited (2015-11-30)

Summary

This is a BVI Financial Services Commission enforcement notice recording that an administrative penalty of $25,000.00 was imposed on Midland Trust Limited for breaches of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008. It is a historical disclosure of a completed enforcement action rather than a rule imposing new ongoing duties on other firms.

• Section 19: Failing to properly engage in or undertake customer due diligence.
• Section 20(2) and (4): Failing to engage in proper enhanced customer due diligence.
• Section 21(1) and (2): Failing to review and keep up to date customer due diligence information in the required manner.
• Section 31(5): Failing to adequately ensure that an introducer reviews and maintains customer due diligence as required.

The matter is identified by Matter ID BF101113/277. No further compliance steps or deadlines are set out for other regulated entities in this notice; it serves as a public record of the penalty and the underlying AML/CFT Code contraventions.

Applies to

trust companies, trust and corporate services providers