JFSC fines SG Kleinwort Hambros firms £719,000
A lack of “robust oversight” and “of documented details of discussions” are the headline findings highlighted in the JFSC’s Public Statement
A lack of “robust oversight” and “of documented details of discussions” are the headline findings highlighted in the JFSC’s Public Statement summarising the fines totalling £719,000 against three SG Kleinwort Hambros firms in Jersey.
A closer review of the statements lists over 30 significant failings identified by the JFSC, that go to the very core of good governance and risk management that boards of any regulated, and indeed unregulated, organisation should be paying close attention to.
The failings are wide ranging and include:
- Lack of overall board oversight of the Compliance and Risk responsibilities, including inadequate risk management systems, evidence of robust discussion of significant compliance matters and a failure to notify the regulators of certain matters requiring notification.
- Significant and material failures because it left the board under informed in terms of Compliance Risk and whether they were operating robust systems and controls to mitigate against financial crimes.
- These include full board oversight, unanswered questions on the adequacy of the resources of the compliance function and its arrangements, management information, and effective compliance monitoring.
The list is endless, and yet based on the information provided at least, many of the shortcomings could have been addressed much earlier and, indeed with good basic governance, could have been avoided entirely.
At Aspida we have a wide range of senior staff and experienced teams within our Business Advisory division to help boards address issues, such as those experienced by Kleinwort Hambros. And as a recognised leader in the Compliance. Risk Management and Assurance space, we can bring you the most up-to-date processes and procedures used within the financial services world.
Our Compliance, Risk Management and Assurance team also provide help and assistance with Cyber Risk Management, AIFMD reporting, MIFiD consultancy, GDPR support, Risk Assessments, and CRS/FATCA (AEOI) reporting. We can also help with supporting Compliance led projects such as client file reviews, board reviews and preparation for regulatory oversight visits. Further, we can provide assurance through periodic controls testing and/or assessment on the internal controls environment.
Our services include:
- Provision of MLRO
- Provision of Compliance Officer
- Provision of MLCO (Guernsey only) and Nominated Officer positions
- Administrative and advisory support to your own MLRO / Compliance Officers / MLCO
- AML and CFT and Regulatory Compliance training
- AML and CFT Business Risk Assessments
- Compliance monitoring (provision or support your existing team)
- Independent assurance of systems and controls
- Enterprise Risk Assessments
- Pre-regulatory visit health checks and remediation programme management
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