PATTON, MORENO AND ASVAT (BVI) LIMITED

An administrative penalty in the amount of $20,000.00 was imposed on PATTON, MORENO AND ASVAT (BVI) LIMITED for its contraventions of the following sections of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008: a) section 20(2) and (4) for failing to engage in proper enhanced customer due diligence; b) section 21(1) and (2) for failing to review and keep up to date customer due diligence information in the required manner; and c) section 31(5) for failing to adequately ensure that an introducer reviews and maintains customer due diligence information as required.