Artemis Trustees Limited (2026-07-03)

Summary

This is a public statement issued by the Guernsey Financial Services Commission (GFSC) disclosing enforcement action taken against Artemis Trustees Limited, a licensed fiduciary company. On 24 June 2022 the Commission decided to impose a financial penalty of £450,000 under section 39 of the Enforcement Powers Law and to publish this statement under section 38 of that Law, following an investigation that began after a full risk assessment in December 2018.

• Financial crime monitoring failures: The Licensee failed to identify red flags on suspicious client activity, failed to carry out ongoing and effective monitoring of high-risk clients, and failed to take reasonable measures to establish source of funds and source of wealth for high-risk customers as required by the Proceeds of Crime Law and the AML/CFT Handbook.
• Beneficial ownership and PEP failings: The Licensee lost track of changes in beneficial ownership of structures it administered, maintained relationships with PEPs and high-risk clients (including individuals linked to sanctions, adverse media and an Interpol Red Notice) without adequate scrutiny, and in one case de-classified a high-risk entity to standard risk without justification.
• Governance and conduct breaches: The Licensee breached the Finance Sector Code of Corporate Governance, the Code of Practice for Trust Service Providers, and the Principles of Conduct of Finance Business, including failing to treat beneficiaries' interests as paramount and failing to deal with the Commission in an open and co-operative manner.
• Periodic review backlog: The Licensee had a significant, repeated backlog of periodic client file reviews (including reviews outstanding since 2002), in breach of its own policy and of Schedule 3 to the Proceeds of Crime Law.
• Sanctions and remuneration risks: The Licensee failed to act on known US sanctions against a client, allowed disguised distributions and disguised remuneration in breach of trust deeds, and accepted substantial gifts and debt settlements via share transfers without adequate controls.

The statement also notes mitigating steps subsequently taken by the Licensee, including strengthening its board, hiring dedicated MLRO/MLCO roles, engaging third-party compliance reviewers, and self-reporting some of the failings. This document is a historical public enforcement disclosure; it does not itself create new ongoing obligations for other regulated entities, though it illustrates the Commission's expectations under existing AML/CFT, corporate governance and trust service provider rules.

Applies to

licensed fiduciaries, trust service providers, financial services businesses