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Monday 24th April 2017
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Comsure operates in:the UK, Jersey, Guernsey

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Jersey – Arrangements to deceive as to beneficial ownership will not be upheld

In Al Tamimi v Al Charmaa(1) the Jersey Royal Court clarified that any arrangement which detracts from the ability of regulators or law enforcement authorities to identify beneficial owners of companies or beneficiaries of trusts will not be recognised on grounds of public policy. Facts The parties to the case were a divorced couple who had been […]

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Money Laundering Regulations 2017: What do the new rules mean for CDD?

Following Treasury’s initial consultation on how to implement MLD4 in September 2016, it has now published the feedback to that consultation and the draft Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the MLR 2017). Time is now running short, and the legislation must be in force by 26 […]

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HOW A HIGH-PROFILE SFO CORRUPTION INVESTIGATION FELL APART

After a revolution overthrew Ukraine’s disgraced president, Theresa May promised to help the country’s new leaders recover stolen assets. But the UK’s first case collapsed within a year. On 11 March 2014, a London branch of the French bank BNP Paribas received a request from a Ukrainian lawyer. He asked the bank to close accounts […]

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JFSC SANCTIONS List by Regime – A List of Jurisdictions Subject to Sanctions – Last Updated: 16 January 2017

The following is a list by regime of sanctions currently in force (in whole or part). For each jurisdiction a brief summary of the remit of each measure is provided but it does not provide an in depth historical background. Where possible, consolidated legislation has been referred to. Where amendments have been made since the […]

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Guernsey – T&Cs and their interpretation in the light of AML obligations.

The Royal Court of Guernsey recently ruled in Jakob International Inc v HSBC Private Bank (CI) Limited on an application by HSBC to strike out a claim brought by its customer, Jakob. Although this was decided without a substantive hearing of all facts, the Court’s decision provides some guidance on terms and conditions (T&Cs) and […]

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FCA on Conduct Risk

The FCA has published; A new webpage on conduct risk programmes which provides information on which programme features are recognised in general by firms as being effective. Copies of the conduct risk programme webpage:  http://bit.ly/2oLuTvL Also, the FCA has published a new webpage on the five conduct questions feedback as part of the FCA’s strategy […]

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Jersey – Arrangements to Deceive as to Beneficial Ownership will not be Upheld

In Al Tamimi v Al Charmaa(1) the Jersey Royal Court clarified that any arrangement which detracts from the ability of regulators or law enforcement authorities to identify beneficial owners of companies or beneficiaries of trusts will not be recognised on grounds of public policy. Facts The parties to the case were a divorced couple who had been […]

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Jersey IT Expert Stephen Goodwin Jailed for Money Laundering in Aug 2016

On the 26 August 2016, it was reported that Stephen Goodwin was jailed for six years at Jersey’s Royal Court An IT expert who laundered almost £600,000 has been jailed for six years. Stephen Goodwin, 51, of St Saviours Road, St Helier, Jersey, illicitly transferred the money between 2006 and 2011 through several jurisdictions, including […]

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