ITI Trade LTD. (in Administration Management) and Mr Alex Phil (2025-07-23)

Summary

This is a public enforcement statement issued by the Guernsey Financial Services Commission (GFSC) under the Financial Services Business (Enforcement Powers) (Bailiwick of Guernsey) Law, 2020. It records the Commission's decisions of 18 July 2025 against ITI Trade LTD (in Administration Management), a former Protection of Investors Law licensee, and Mr Alex Phil (formerly Mr Alexei Filatov), a former director and MLRO of the firm, following an investigation into widespread and systemic AML/CFT, customer due diligence and corporate governance failings.

• Financial penalties: A £175,000 penalty was imposed on the Licensee and a £35,000 penalty on Mr Phil under section 39 of the Enforcement Powers Law.
• Prohibition order: Mr Phil was prohibited from holding a supervised role for 2 years and 10 months under section 33(1) of the Enforcement Powers Law.
• Disapplication of exemption: The exemption in section 3(1)(g) of the Regulation of Fiduciaries etc. Law, 2020 was disapplied in respect of Mr Phil for the same 2 years and 10 month period, under section 32(3).
• Findings against the firm: Failure to conduct and periodically review relationship risk assessments, failure to identify persons on whose behalf customers acted, failure to carry out CDD and enhanced CDD, failure to identify PEPs, failure to monitor transactions, and inadequate AML/CFT policies, procedures and controls.
• Corporate governance failings: Breaches of the Licensees (Conduct of Business) Rules 2016, the Finance Sector Code of Corporate Governance and the Principles of Conduct of Finance Business, largely arising from inadequate oversight of an almost fully outsourced business model.
• Findings against Mr Phil: Failure to act with probity and competence, including materially altering a third-party compliance report before submitting it to the Commission, which misled the Commission about the true extent of identified deficiencies.

The statement is published as a public record of a concluded enforcement matter rather than as a document creating new ongoing regulatory requirements; it illustrates the standards the Commission expects licensees and individuals in supervised roles to meet under Schedule 3, the Handbook, the COB Rules and the POI Law.

Applies to

Protection of Investors Law licensees, investment firms providing execution only and prime brokerage services, directors and Money Laundering Reporting Officers (MLROs) of licensed firms