Print Article

GFSC issue a £7k fine on a NED - Stephen Paul Dewsnip (“Mr Dewsnip”) - 27 July 2020


On 27 July 2020, the Guernsey Financial Services Commission (the “Commission”) decided:

  1. To impose a financial penalty of £7,000 under section 11D of the Financial Services Commission Law on Mr Dewsnip; and
  2. To make a public statement under section 11C of the Financial Services Commission Law.

The Commission considered it reasonable, proportionate and necessary to make these decisions having concluded that Mr Dewsnip failed to fulfil the minimum criteria for licensing under Schedule 7 to the Insurance Law.

  1. The actions of Mr Dewsnip could have seriously put at risk the payment of claims to policyholders and therefore could have posed a risk to the reputation of the Bailiwick as an international finance centre.
  1. Mr Dewsnip was a non-executive director of Global Insurance Group Limited (“GIGL”), which was licensed under the Insurance Law. Mr Dewsnip was a director of GIGL from 21 December 2011 to 25 August 2016.
  2. Under an agreement between GIGL and a United Kingdom intermediary (which had some common ownership with GIGL) (“Intermediary A”),
    • Intermediary A issued insurance policies on behalf of GIGL.
    • Intermediary A was also able to collect premiums from policyholders on behalf of GIGL and retain a portion of the premiums as a loss fund to pay claims on behalf of GIGL (“the Claim Fund”).
    • Bordereaux reports (a list, or summary, of policies issued and premiums charged and/or claims paid) should have been prepared monthly by Intermediary A and net premium settlements made quarterly to GIGL.
  1. The Commission conducted a risk assessment visit to GIGL in July 2017 (“the July 2017 Visit”).
  2. As a result of the July 2017 Visit, the Commission had concerns over GIGL’s oversight of functions outsourced to Intermediary A, in particular the management of the Claims Fund.
  3. The Commission also found that GIGL had not conducted any audit of the activity carried out by Intermediary A and could not adequately monitor the solvency of GIGL due to the frequency of reporting from Intermediary A.
  4. GIGL began to request that the payments be regularised from November 2015 onwards.
  5. However, regular payments from Intermediary A were not forthcoming.
  6. The outstanding amounts were only paid to GIGL after intervention by the Commission and after investment into Intermediary A by a third party. This called into question the liquidity of GIGL’s major asset.
  1. As a director of GIGL, Mr Dewsnip failed to ensure the implementation of effective systems of control, in particular in relation to the Claims Fund held by, and the Bordereaux reporting from, Intermediary A.
  2. As a director of GIGL, Mr Dewsnip also failed to ensure that the amounts due from Intermediary A were paid to GIGL in a timely manner.


The Team

Meet the team of industry experts behind Comsure

Find out more

Latest News

Keep up to date with the very latest news from Comsure

Find out more


View our latest imagery from our news and work

Find out more


Think we can help you and your business? Chat to us today

Get In Touch

News Disclaimer

As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email