Member details withheld

Member details withheld 

Complaint

The allegations were that the respondent has failed to: 

  1. carry out and provide evidence of a firm risk assessment in accordance with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) Regulation 18; 
  2. establish, document and review anti-money laundering policies, procedures and controls in accordance with MLR 2017 Regulation 19;  
  3. ensure adequate internal controls in accordance with MLR 2017 Regulation 21; 
  4. take appropriate measures to ensure that its relevant employees are made aware of the requirements of MLR 2017 and given relevant training in accordance with MLR 2017 Regulation (24 (1)); 
  5. carry out customer due diligence (CDD) on clients in accordance with MLR 2017 Regulation 27 (1)(a) and Regulation 28;  
  6. provide requested information or documents in accordance with MLR 2017 Regulation 66; and/or 
  7. provide such information as is deemed necessary by the Institute for compliance and monitoring purposes in accordance with IFA Bye-law 12.2. 

Finding

The Regulatory Committee found that there was sufficient evidence that facts and circumstances had occurred that rendered the respondent liable to disciplinary action under IFA Bye-law 11.2 (c) and/or (d) for breaches of IFA Bye-law 12.2 and Money Laundering Regulations 2017 18, 19, 21, 24 (1), 27(1)(a), 28 and 66.

Consent Order

Severe Reprimand, fine of £7,500 and costs of £651.