The Guernsey Financial Services Commission has published a public statement on its 2 February 2023 decision to fine William Stephen Cairns GBP 133,000 and Du Preez Gert Vermeulen GBP 35,000 and to ban them from licensed fiduciary roles for 10 years and six months and two years and one month respectively. It found that the former directors of a Guernsey fiduciary licensee failed to ensure compliance with AML and counter-terrorist financing, conduct and minimum licensing requirements, in failings the Commission said were serious, predominantly pre-2018 and capable of harming Guernsey’s reputation as an international finance centre. The case followed an investigation opened in March 2018 after on-site visits in November 2015 and July 2017 found serious and systemic weaknesses that were not adequately remediated despite Risk Mitigation Programmes. The Commission identified misleading client agreements and statements that omitted key third parties, inadequate monitoring of trust activity including approximately GBP 16 million sent over five years to a foreign bank account whose holder the licensee could not identify, and the purchase of about USD 28 million of shares for a trust without the necessary due diligence, which later became worthless. It also found inaccurate or incomplete records of settlors and beneficiaries, missing client agreements over 26 years, large backlogs in financial accounts, delayed statutory reporting, and an unmanaged conflict of interest linked to a personal loan from Mr Cairns to Mr Vermeulen. The Commission also disapplied each man’s exemption under the fiduciaries law for the same period as the relevant prohibition, while co-operation and early settlement were reflected in discounted sanctions.