The Guernsey Financial Services Commission issued a public statement setting out enforcement action against ITI Trade LTD (in Administration Management) and its former director Mr Alex Phil, after concluding they failed to comply with regulatory requirements and did not meet the minimum criteria for licensing. The Commission imposed financial penalties of GBP 175,000 on the firm and GBP 35,000 on Mr Phil, prohibited Mr Phil from holding a supervised role for 2 years and 10 months, and disapplied a fiduciary-business exemption in respect of him for the same period. The investigation found serious and systemic AML/CFT and corporate governance failings linked to an extensively outsourced operating model in which much of the business was conducted in Russia. Identified breaches included inadequate relationship risk assessments and reviews, deficient customer due diligence and enhanced due diligence (including source of funds and wealth), failure to identify politically exposed persons, and lack of evidence of effective ongoing monitoring of customer activity and transactions. The Commission also highlighted the firm’s treatment of its Russian sister company as a customer while not identifying the 108 underlying individuals for whom it acted, despite this relationship accounting for over 75% of assets under management as at July 2022, and noted that assets under management increased by over 440% in early 2022 without recorded board-level consideration or a corresponding reassessment of customer risk. For Mr Phil, the Commission concluded he did not consistently act with probity, competence, sound judgement and diligence, and that he misled the regulator by submitting a materially altered letter from a third-party compliance service provider that omitted significant deficiencies. Aggravating factors included the high-risk customer base and repeated opportunities to remediate through risk mitigation programmes, while mitigating factors included voluntary surrender of the licence, the appointment of administration managers in 2022 and early settlement, which was reflected in discounts to the penalties and prohibition duration.
Guernsey Financial Services Commission 2025-07-23
Guernsey Financial Services Commission fines ITI Trade GBP 175,000 and Alex Phil GBP 35,000 and bars him from supervised roles for 2 years 10 months
The Guernsey Financial Services Commission took action against ITI Trade LTD and former director Alex Phil for regulatory failures, imposing penalties of GBP 175,000 on the firm and GBP 35,000 on Phil. The investigation found systemic AML/CFT and corporate governance failings, including inadequate risk assessments and customer due diligence, linked to an outsourced model in Russia. Phil was banned from a supervised role for nearly three years for misleading the regulator and lacking competence and diligence.