Mr Ian Charles Domaille, Mr Ian Geoffrey Clarke and Mrs Margaret Helen Hannis (2026-07-03)

Summary

This is a Guernsey Financial Services Commission public statement announcing enforcement action against three individuals connected to a licensed Guernsey fiduciary company, following an investigation into serious and repeated anti-money laundering and beneficial ownership failings. It is a completed enforcement decision, not an ongoing rulemaking, and imposes financial penalties and a public statement rather than new rules for the wider industry.

• Financial penalties imposed: Under section 39 of the Enforcement Powers Law: £125,000 on Mr Ian Charles Domaille, £40,000 on Mr Ian Geoffrey Clarke, and £22,500 on Mrs Margaret Helen Hannis.
• Public statement: The Commission also decided to make this public statement under section 38 of the Enforcement Powers Law.
• Basis for action: The Commission found the individuals failed to ensure the Licensee complied with AML/CFT regulations, the Handbook rules, the Code of Corporate Governance and the TSP Code, and failed to meet the Minimum Criteria for Licensing under Schedule 1 of the Fiduciaries Law.
• Nature of failings: Findings included inadequate identification of beneficial owners and source of funds, failure to manage conflicts of interest, inadequate ongoing monitoring and periodic file reviews, failure to conduct enhanced due diligence for high-risk and PEP relationships, and inadequate risk classification reviews.
• Mitigating factors: The Licensee undertook a risk mitigation programme, appointed additional directors including a new CEO and non-executive director, and expanded compliance resources including hiring a separate MLRO and MLCO.

This document is a historical enforcement notice concerning named individuals and does not itself create new ongoing compliance obligations for other licensees, though it illustrates the Commission's expectations under existing AML/CFT and fiduciary licensing regimes.

Key obligations

• Mr Domaille must pay a financial penalty of £125,000 imposed under section 39 of the Enforcement Powers Law
• Mr Clarke must pay a financial penalty of £40,000 imposed under section 39 of the Enforcement Powers Law
• Mrs Hannis must pay a financial penalty of £22,500 imposed under section 39 of the Enforcement Powers Law

Applies to

fiduciary licensees, trust and corporate service providers, directors and controllers of licensed fiduciary companies