Ms Ginette Louise Blondel (2024-03-06)

Summary

This is a Guernsey Financial Services Commission public statement announcing enforcement action against an individual, Ms Ginette Louise Blondel, for carrying out regulated fiduciary activities without a licence. It is not a rule-making instrument; it records the Commission's findings and sanctions following an investigation and has no ongoing compliance requirements for other firms, though it illustrates how the Commission applies the Fiduciaries Law, the AML/CFT Regulations and Handbook, and the Company Director Code.

• Financial penalty: A £210,000 financial penalty was imposed on Ms Blondel under section 39(1) of the Enforcement Powers Law.
• Prohibition order: A Prohibition Order was made under section 33(1) of the Enforcement Powers Law barring her from acting as controller, director, partner, manager, money laundering reporting officer or money laundering compliance officer for 9 years and 1 month.
• Disapplication of exemption: The exemption in section 3(1)(g) of the Fiduciaries Law was disapplied in respect of her for the same 9 year 1 month period, under section 32 of the Enforcement Powers Law.
• Public statement: The statement itself was issued under section 38(1) of the Enforcement Powers Law as a public disclosure of the findings and sanctions.
• Findings: The Commission found she carried out trust and company administration, acted as director and company secretary, and advised on trust and company matters by way of business without holding a fiduciary licence, in breach of the Fiduciaries Law, and that she lacked required AML/CFT policies, procedures and controls in breach of Regulations 3, 5, 11 and 15 and the Handbook, and breached Principle 7 of the Company Director Code.

The document is a completed enforcement outcome relevant to fiduciary licensees and individuals for reference on regulatory expectations; it does not impose new ongoing obligations on the wider industry.

Applies to

individuals carrying out fiduciary or company/trust administration activities, fiduciary licensees, company directors, persons subject to the Fiduciaries Law and AML/CFT Regulations