Garfield Bennett Trust Company Limited (2025-08-06)

Summary

This is a JFSC public statement announcing enforcement action against Garfield Bennett Trust Company Limited (GBTCL), a designated service provider (DSP) to five Jersey Private Funds (JPFs). The JFSC imposed a civil financial penalty for negligent contraventions of the Trust Company Business Code and AML/CFT Code between October 2020 and March 2022, relating to inadequate risk management, due diligence and governance in respect of the Funds.

• Penalty: A civil financial penalty of £86,803.19 was imposed on GBTCL on 31 July 2025 under the Financial Services Commission (Jersey) Law 1998, reflecting a 50% Stage One discount for early settlement.
• Findings: GBTCL lacked bespoke JPF policies and procedures, failed to conduct adequate business risk assessments and customer due diligence, failed to promptly appoint a DSP, MLRO and MLCO after Funds A-D converted to JPFs, failed to monitor transactions or reconcile Fund A's bank account, mismanaged conflicts of interest, and kept poor records.
• Outcome: No customer or investor loss was identified, but the contraventions were deemed significant and material due to increased financial crime risk exposure; GBTCL has since ceased providing JPF services and strengthened its board governance.

The statement is issued as a public notice for informational and deterrence purposes and does not itself create new ongoing regulatory requirements beyond the sanction already imposed on GBTCL.

Applies to

trust company business providers, designated service providers (DSPs) to Jersey Private Funds, supervised persons under the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008