Circle Investment Support Services (BVI) Ltd.

An administrative penalty in the amount of $20,000.00 was imposed on Circle Investment Support Services (BVI) Ltd. for its contravention of the following sections of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008: a) section 12 for failing to establish a written system of internal controls, to undertake money laundering and terrorist financing risk assessments in relation to each customer, business relationship, or one-off transaction; b) section 19(5) for failing to carry out due diligence on a legal person and collect identification on a legal person and the underlying principals of legal persons; and c) sections 21(1), (2) and (4) for failing to review and keep up-to-date customer due diligence information in the required manner.