The Guernsey Financial Services Commission has published a public statement on its 4 June 2026 decision to impose financial penalties of GBP 125,000 on Mr Domaille, GBP 40,000 on Mr Clarke and GBP 22,500 on Mrs Hannis for failings at a licensed Guernsey fiduciary company. The Commission found that they failed to ensure the licensee complied with regulatory requirements and failed to meet the Minimum Criteria for Licensing under the Fiduciaries Law. The breaches covered ongoing monitoring, source of funds and source of wealth checks, customer risk assessments, ownership and control reviews, conflicts of interest and internal controls. The case followed a December 2018 full risk assessment that identified weak beneficial ownership and source of funds checks, failures to identify and manage conflicts, and a significant backlog of file review actions. The Commission highlighted high-risk client relationships in which the licensee continued to act despite unresolved source of funds concerns, adverse media, U.S. sanctions and politically exposed person exposures, including reclassifying a structure linked to a politically exposed person from high risk to standard risk without properly considering ownership changes or sanctions risk. It also cited payments made outside a charitable trust's purposes, failures to establish the provenance of loans and other incoming funds, acceptance of gifted shares that created unmanaged conflicts, and inadequate controls over funds linked to cryptocurrency activity. In relation to Mrs Hannis, the Commission concluded that her actions meant she was not a fit and proper person. As mitigating factors, the Commission noted remediation after its 2018 on-site visit, including a risk mitigation programme, additional directors, a chief executive officer independent of the ownership, a new non-executive director, and expanded compliance resources including separate MLRO and MLCO roles.
Guernsey Financial Services Commission2026-07-03
Guernsey Financial Services Commission fines three individuals GBP 187500 over fiduciary AML and governance failings
The Guernsey Financial Services Commission has fined Mr Domaille, Mr Clarke and Mrs Hannis GBP 125,000, GBP 40,000 and GBP 22,500 for failings at a licensed fiduciary company. The case covers weak AML and fiduciary controls, including poor monitoring of high-risk and politically exposed person clients, inadequate source of funds checks, flawed risk classification, unmanaged conflicts and deficient trust administration. The Commission also concluded that Mrs Hannis is not a fit and proper person.