Midland Trust Limited

A warning was issued to Midland Trust Limited for its contraventions of: Section 34(2) of the Financial Services Commission Act, 2001, for failing to establish and maintain a compliance procedures manual complying with therequirements specified in section 41 of the Regulatory Code, 2009; Section 13(2)(d)(ii) of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008, for failing to establish appropriate mechanisms thatenable the recognition of transactions which raise a suspicion that the money involved may be a proceed of a criminal conduct, drug trafficking or money laundering or may relate to a financing of terrorist activity and sections 15(c) and 15(d) of the Anti-Money Laundering Regulations, 2008, for failing to set out in its procedures that the MLRO will have reasonable access to all relevant information; Section 12 of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 and regulation 4(2)(d) of the Anti-Money Laundering Regulations, 2008 for failing to conduct the necessary risk assessment of all applicants for business to ensure that the appropriate level of monitoring is administered to those that present higher risks; Section 48(1) of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008, for failing to provide its employees at appropriate frequencies with adequate training in the recognition and handling of transactions, having regard to regulations 16(1) and (2)of the Anti-Money Laundering Regulations, 2008; Section 160(2)(e) of the Regulatory Code, 2009 for failing to maintain the required minimum professional indemnity insurance coverage of a Class 1 Trust licence holder; and Sections 20(1) and 21(a) of the Regulatory Code, 2009, for failing to ensure that the Compliance policy was appropriate for the nature, scale and complexity of the business.