MWM Financial Services Group Limited

A warning letter was issued to MWM Financial Services Group Limited for its contravention of the following legislation: (a) regulation 11 of the Anti-Money Laundering Regulations, 2008 (AML Regulations) and section 42(1) of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 (AMLTFC) by failing to maintain its records in accordance with the Regulatory Code, 2009 (the Regulatory Code) and the AMLTFC; (b) section 13(2)(d) of the AMLTFC by failing to put a mechanism in place within its internal control system to recognise and report a transaction which raises a suspicion that the money involved may be proceeds of criminal conduct; (c) section 20 of the AMLTFC by failing to conduct enhanced due diligence of higher risk clients; (d) section 47(1)(b) of the AMLTFC by failing to employ a system of testing employees; awareness and understanding of information received from the training; and (e) sections 27(1)(a) and 27(2) of the Regulatory Code by failing to: (i) put business continuity arrangements in place aimed at ensuring that the licensee is able to continue to carry on its regulated business; (ii) meet its regulatory and AML/CFT obligations; and (iii) have a business continuity policy and arrangements that are appropriate for the nature, size and complexity, structure of the licensee;s business and the types and degree of risk to which it is exposed.