Administrative Penalty $31,500.00 - Mossack Fonseca & Co. (B.V.I.) Ltd. (2016-11-04)

Summary

This is a published enforcement action notice from the British Virgin Islands Financial Services Commission (FSC) disclosing that it imposed an administrative penalty of $31,500.00 on Mossack Fonseca & Co. (B.V.I.) Ltd. The notice sets out the specific regulatory contraventions found, but it is a historical record of a completed enforcement action rather than a document creating ongoing obligations for other firms.

• Business continuity: Failure to establish a business continuity policy as required by section 27(1) of the Regulatory Code, 2009.
• Controls and systems: Failure to have adequate controls and reliable, secure information systems under sections 29(2)(k), 30(3), 31 and 32 of the Regulatory Code.
• Customer due diligence: Failure to properly conduct customer due diligence under section 19(2) of the AML/TF Code, 2008.
• Enhanced due diligence: Failure to conduct proper enhanced customer due diligence under section 20 of the AML/TF Code.
• Updating due diligence: Failure to review and keep customer due diligence information up to date as required by section 21 of the AML/TF Code.
• Certified documents: Failure to ensure due diligence document copies were properly certified, contrary to section 30 of the AML/TF Code.

The matter is identified by the FSC as Matter ID BF101113/297. The notice does not impose any new requirements on other regulated entities; it serves as public disclosure of the penalty and the underlying breaches found against this specific firm.

Applies to

Trust and Corporate Services Providers