IQ EQ (Jersey) Limited (formerly, First Names (Jersey) Limited) (2022-07-01)

Summary

This is a JFSC public statement announcing a civil financial penalty against IQ EQ (Jersey) Limited (formerly First Names (Jersey) Limited), a registered trust company business. The penalty of £803,661.17 was imposed on 17 June 2022 following findings from an independent reporting professional's targeted review of 16 customer structures covering the period 1 January 2018 to 29 November 2019.

• Nature of breaches: The JFSC found IQ EQ Jersey negligently breached the AML/CFT Code and the TCB Code, including failures to maintain an up-to-date business risk assessment, assess and act on control deficiencies, apply risk-based CDD, keep adequate CDD records, act with due skill and care, obtain sufficient information to exercise discretion, conduct robust periodic customer reviews, ensure adequate board-level oversight, comply with AML/CFT legislation, and confirm services to customers in writing.
• Discount applied: IQ EQ Jersey settled early and received a 50% Stage One discount, reducing the penalty from a potential £1,607,322.34.
• Purpose of statement: The JFSC issued this statement under Article 25(ba) of the FS(J)L and Article 26(ba) of the Supervisory Bodies Law to protect Jersey's reputation and counter financial crime, not to impose new rules.

This is a historical enforcement notice concerning a specific firm's past conduct; it does not create new ongoing regulatory requirements for other entities, though it illustrates the JFSC's expectations under the AML/CFT Code and TCB Code regarding business risk assessments, CDD/EDD, board oversight, and record-keeping.

Applies to

trust company business