Enforcement Action

Enforcement Action: Administrative Penalty $31,500.00
Name of Entity: Mossack Fonseca & Co. (B.V.I.) Ltd.
Date of Action: 11/04/2016

An administrative penalty in the amount of $31,500.00 was imposed on Mossack Fonseca & Co. (B.V.I.) Ltd. for its contravention of the following sections of the Regulatory Code, 2009 (the “Reg. Code”) and the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 (the “AMLTF Code”):

a)    section 27(1) of the Reg. Code for failing to establish a business continuity policy in accordance with the Regulatory Code;

b)     section 29(2)(k), 30(3), 31 and 32 of the Reg. Code for failing to have in place adequate controls and reliable and secure information systems;

c)      section 19(2) of the AMLTF Code for failing to properly engage in or undertake customer due diligence;

d)    section 20 of the AMLTF Code for failing to engage in proper enhanced customer due diligence;

e)    section 21 of the AMLTF Code for failing to review and keep up-to-date customer due diligence information in the required manner; and

f)    section 30 of the AMLTF Code for failing to ensure that the copies of due diligence documents relied upon were properly certified.