Warning Letter - MWM Financial Services Group Limited (2016-10-27)

Summary

This is a public enforcement notice issued by the British Virgin Islands Financial Services Commission (BVI FSC), recording that a warning letter was sent to MWM Financial Services Group Limited for multiple contraventions of anti-money laundering and regulatory requirements. It is informational only, documenting a completed enforcement action against a named licensee rather than creating new rules for the industry.

• Record-keeping: Failure to maintain records in accordance with the Regulatory Code, 2009 and the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 (AMLTFC), contravening regulation 11 of the AML Regulations, 2008 and section 42(1) of the AMLTFC.
• Suspicious activity monitoring: Failure to have an internal control mechanism to recognise and report transactions suspected to involve proceeds of criminal conduct, contravening section 13(2)(d) of the AMLTFC.
• Enhanced due diligence: Failure to conduct enhanced due diligence on higher risk clients, contravening section 20 of the AMLTFC.
• Staff training: Failure to test employees' awareness and understanding of AML training received, contravening section 47(1)(b) of the AMLTFC.
• Business continuity: Failure to put in place adequate business continuity arrangements and policy appropriate to the nature, size, complexity and risk profile of the business, and failure to meet regulatory and AML/CFT obligations, contravening sections 27(1)(a) and 27(2) of the Regulatory Code.

The notice identifies the matter reference (Matter ID: BF101113/321) but does not set out any further sanctions, remediation deadlines, or continuing obligations beyond the warning itself.

Applies to

MWM Financial Services Group Limited (licensee)