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Comsure operates in:the UK, Jersey, Guernsey


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Improving the suitability of financial advice – Fact finding and reporting

The following Speech by Debbie Gupta, Director of Life Insurance and Financial Advice Supervision at the FCA, delivered at Money Marketing Interactive Conference 2019, Harrogate addressed the thorny issue of Improving the suitability of financial advice – Fact finding and reporting The full speech is linked below, and the following extract provides some thought leadership […]

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Why does the compliance function/officer struggle (and in some case fail?)

There are various reasons why compliance officers fail. Reason my range from personal to professional attributes. Below are 10 reason why compliance officers fail. 1. Pushback from the general counsel. A very entrenched general counsel is likely to have built up a strong reputation within their company as someone who is close with and sympathetic […]

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Nato: Cyber-attack on one nation is attack on all

Nato Secretary General Jens Stoltenberg says all 29 member countries would respond to a serious cyber-attack on one of them. Writing in Prospect Magazine, he said such an incident would trigger a “collective defence commitment”, known as Article 5 of its founding treaty. Article 5 has not been triggered since the 9/11 terror attacks on […]

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Jersey rule Changes on Customers Acting for Third Parties – Article 17 Money Laundering (Jersey) Order 2008

Many financial services businesses in Jersey ( “relevant business or businesses”) which are subject to the requirement to carry out due diligence on their customers under the Money Laundering (Jersey) Order 2008 (“MLJO”) have historically placed a considerable measure of reliance on being able to operate a simplified due diligence process. This process is in respect of […]

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Chinese Banks to Produce Documents in Money Laundering Case says DC Circuit Court

On July 30, 2019, the US Court of Appeals for the DC Circuit unanimously upheld a district court order requiring three unnamed Chinese banks to produce financial records subpoenaed by US federal prosecutors. Although the US government does not currently suspect that the subpoenaed banks took part in wrongdoing, the banks were allegedly used by […]

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N v RBS: Terminating a banking relationship without notice where money laundering is suspected

What has happened? On 8 July 2019, the English High Court handed down judgment in proceedings between N and The Royal Bank of Scotland plc (“RBS“) ([2019] EWHC 1770 (Comm)). Following the conclusion of related proceedings brought by the National Crime Agency (“NCA“), the court was required to consider whether RBS had acted lawfully in freezing […]

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Guernsey firm named in UKs first UWO CASE

A Blomberg’s article “Dirty Money Spotlights Role of Family Offices as Enablers” identifies a Guernsey trust company in the web of structures involving Jahangir Hajiyev and his wife, Zamira who is subject to the UKs first UWO • https://www.bloomberg.com/news/features/2019-07-30/dirty-money-spotlights-role-of-family-offices-as-enablers THE Blomberg’s story provides the following facts and observations: Introduction 1. Jahangir Hajiyev was convicted of […]

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Jersey Ex-JFSC employee fined after disclosing company’s documents (Jul 17, 2019)

A FORMER Jersey Financial Services Commission employee who took confidential documents from an application file, and then presented them to his subsequent employer as the ‘gold standard’ for such paperwork, has been spared prison. Accountant Timothy Owen Jones, of St Peter, pleaded guilty in the Magistrate’s Court to one count of disclosing information about Belasko […]

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