The Commission launched an investigation following a visit in 2021 where breaches of regulatory requirements were found in 70% of the client files reviewed. 

The following failures were subsequently highlighted: 

A failure to regularly review relationships risk assessments 

The Commission found that half of the reviewed files had been inappropriately risk assessed. One example being a client who was incorrectly assessed as low to medium risk, despite several media outlets identifying the client in relation to bribery and corruption. 

A failure to understand the ownership and control structure of a customer 

All files that fell under review were found to be deficient in customer due diligence. 

A failure to comply with the regulations and rules surrounding Introducer Relationships 

A failure to carry out Enhanced Customer Due Diligence and Enhanced Measures 

A failure to monitor activity and transactions 

A failure to ensure the firm had appropriate Anti-Money Laundering procedures 

The firm’s Board of Directors and systems of governance were ineffective 

“The numerous examples of non-compliance with applicable laws, regulations, rules, codes and principles evidenced by the Commission above, demonstrate that the board of the Licensee failed to effectively direct and supervise the affairs of the business,” said The Commission. 

“Information provided to the board by third party compliance consultants, as well as its own compliance staff and internal consultants was not adequately considered and acted upon to ensure that the Firm’s failings were remediated and recurrence prevented.” 

A failure to minimise conflicts of interest  

A failure of the directors to act in the best interests of the company 

Fides Corporate Services Limited: Was fined £140,000 

Mr Whitworth: Was fined £70,000 

Mr Conway: Was fined £35,000 

Mr Turner: Was fined £21,000 

Additionally, Mr Conway and Mr Whitworth were banned from holding supervised roles for several years. 

You can read the full report ONLINE.