MOSSACK FONSECA & CO (B.V.I.) LTD.

An administrative penalty in the total amount of $440,000.00 was imposed on MOSSACK FONSECA CO (B.V.I.) LTD. for its contravention of sections 11, 12, 19(2), 19(4), 19(5), 20, 21(1), 21(2), 31, and 43(2) of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 and sections 43(2)(c), 43(3)(a), 43(3)(c) and 45(1)(a) of the Regulatory Code, 2009: 1.Section 11 of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 for failing to establish and maintain a written and effective system of internal controls for forestalling and preventing money laundering and terrorist financing; 2.Section 12 of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 for failing to carry out risk assessments in relation to each customer/one-off transactions; 3.Section 19(2), 19(4) and 19(5) of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 for failing to undertake customer due diligence; 4.Section 20 of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 for failing to engage in enhanced customer due diligence; 5.Section 21(1) and 21(2) of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 for failing to review and update customer due diligence in the manner required; 6.Section 31 of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 for failing to ensure identification and verification is carried out with respect to written introductions by third parties; 7.Section 43(2) of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 for failing to maintain due diligence and identity records; and 8.Sections 43(2)(c), 43(3)(a), 43(3)(c) and 45(1)(a) of the Regulatory Code, 2009 for failing to carry out obligations, duties and responsibilities of the compliance officer.