Heritage Insurance Company (Caribbean) Limited

An administrative penalty in the amount of $20,000.00 was imposed on Heritage Insurance Company (Caribbean) Limited for its contraventions of the following sections of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008: a) section 11(1), 11(3), and 11(3A) for failing to establish and maintain appropriate policies, procedures, and processes for forestalling and preventing money laundering and terrorist financing, failure to maintain an effective system of internal controls, and failure to establish and maintain an independent audit function that is adequately resourced to test compliance; b) section 19(2) for failing to engage in or undertake customer due diligence; and c) section 48(2) for failing to provide training to its directors and employees, and maintain a Training Register.