meta_id 3271528

On June 25, 2026, the Financial Intelligence Analysis Unit (FIAU) imposed a Remediation Directive on an investment services provider following a full-scope compliance examination conducted in 2022. The directive was issued under Regulation 23(1)(c) of the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) and addresses multiple breaches of anti-money laundering and counter-terrorism financing (AML/CTF) obligations. The FIAU's Compliance Monitoring Committee identified significant deficiencies across the company's AML/CTF framework. Key findings included: the absence of timely Board-approved Business Risk Assessments (BRA) from January 1, 2018 onwards; inadequate and overly subjective Customer Risk Assessment (CRA) methodology lacking objective scoring criteria; failure to conduct Customer Due Diligence (CDD) at onboarding in certain instances; insufficient verification of Source of Wealth and Source of Funds, particularly for high-risk customers; incomplete ongoing transaction monitoring that did not adequately assess consistency with customer profiles; lapses in periodic review and updating of customer documentation; and deficient record-keeping systems resulting in data omissions and inconsistencies. The Committee determined these breaches were of generally low materiality, affecting a limited number of customer files rather than being systematic. The Committee acknowledged that many issues were historical and that the company had already undertaken remediation efforts prior to the directive's imposition. The Remediation Directive requires the company to strengthen its BRA, implement consistent risk assessment methodologies, ensure proper customer identification and verification, enhance transaction monitoring frameworks, and maintain consolidated and retrievable client records. The company must demonstrate sufficient tangible progress within stipulated timeframes. Failure to comply may result in administrative penalties under Regulation 21(1) of the PMLFTR.