Midland Trust Limited

An administrative penalty in the amount of $25,000.00 was imposed on Midland Trust Limited for its contravention of the following sections of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008: a) section 19 for failing to properly engage in or undertake customer due diligence; b) section 20(2) and (4) for failing to engage in proper enhanced customer due diligence; c) section 21(1) and (2) for failing to review and keep up to date customer due diligence information in the required manner; and d) section 31(5) for failing to adequately ensure that an introducer reviews and maintains customer due diligence as required.