Mr Iskander Karam (2024-02-07)

Summary

This is a public enforcement statement issued by the Guernsey Financial Services Commission against Mr Iskander Karam (also known as Alexander Karam or Alexander Kaymen), a former controller of a licensed investment manager and director of an authorised collective investment scheme. The Commission found that Mr Karam deliberately or recklessly made false or misleading statements in his Personal Questionnaire submitted in 2018, in breach of section 38(2) of the Protection of Investors (Bailiwick of Guernsey) Law, 1987, and that he failed to meet the fit and proper criteria under the 2020 POI Law.

• Financial penalty: A £10,000 financial penalty imposed under section 39 of the Enforcement Powers Law.
• Prohibition order: An order under section 33 of the Enforcement Powers Law prohibiting Mr Karam from performing any function in relation to regulated financial services business for two years.
• Exemption disapplied: A notice under section 32 of the Enforcement Powers Law disapplying the exemption in section 3(1)(g) of the Fiduciaries Law in respect of Mr Karam for two years.
• Public statement: Issuance of this public statement under section 38 of the Enforcement Powers Law, detailing the false or misleading representations made about his employment history, job description and other relevant experience.

This is an individual enforcement action rather than a general rule change; it does not impose new ongoing obligations on the wider industry, but serves as a warning regarding the seriousness with which the Commission treats false or misleading statements in Personal Questionnaires and licensing applications.

Applies to

investment managers, collective investment schemes, individuals holding controlled functions or prescribed positions

Deadlines

• two years from 23 January 2024: Duration of the prohibition order against Mr Karam preventing him from performing any function in relation to regulated financial services business.
• two years from 23 January 2024: Duration for which the exemption under section 3(1)(g) of the Fiduciaries Law is disapplied in respect of Mr Karam.