Weighbridge Trust Limited, Mr Paul Conway, Mrs Linda Dowding (2026-05-14)

Summary

This is a public enforcement statement issued by the Guernsey Financial Services Commission (GFSC) detailing findings and sanctions against Weighbridge Trust Limited and two former directors, Mr Paul Conway and Mrs Linda Dowding. It describes historic (predominantly pre-2018) failures in AML/CFT controls, record keeping, integrity and conflict of interest management identified through onsite visits and investigation, and the penalties imposed as a result.

• Mr Conway: Financial penalty of £30,000, a three-year prohibition from any function, and disapplication of the section 3(1)(g) exemption under the 2020 Fiduciaries Law for three years (decided 4 August 2023).
• Mrs Dowding: Financial penalty of £40,000, a three-year prohibition from any function, disapplication of the section 3(1)(g) exemption for three years, and issuance of this public statement (decided 26 September 2023).
• Findings against the Licensee: Failure to act with integrity and probity, failure to observe fiduciary duty to beneficiaries, failure to monitor client activity and transactions, failure to keep proper books and records, failure to maintain effective AML/CFT procedures, and failure to manage conflicts of interest.
• Mitigating factors: The current board and controllers, appointed after the relevant period, have fully remediated the business; all licence conditions and Risk Mitigation Programmes from a 2017 onsite visit have been lifted or completed, and both the Licensee and the individuals cooperated fully with the Commission.

The statement is retrospective and informational: it records enforcement decisions already taken against the individuals concerned (no penalty was imposed on the Licensee itself, which the Commission notes it would otherwise have penalised but for the remediation carried out). It does not impose new prospective obligations on other firms, though it illustrates the standards (integrity, fiduciary duty, monitoring, record keeping, AML/CFT compliance, conflict of interest management) that the Commission expects fiduciary licensees and their directors to meet under the Enforcement Powers Law, the 2020 Fiduciaries Law, the Proceeds of Crime Regulations 2007 and the Handbook for Financial Services Businesses.

Applies to

fiduciary licensees, trust service providers, corporate service providers, licensed directors and controllers, MLROs