Portcullis TrustNet (BVI) Limited

An administrative penalty in the total amount of $205,500.00 was imposed on Portcullis TrustNet (BVI) Limited for the following contraventions: Section 11 of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 for its failing to maintain appropriate policies, procedures and other measures to prevent misuse of technological developments; Section 12 of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 for failing to carry out money laundering and terrorist financing risk assessments; Section 14(2) of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 for failing to comply with the measures under section 14(2) (responsibilities of senior management); Section 20 of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 for failing to engage in enhanced customer due diligence; and Section 21(1), (2) and (3) of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 for failing to review and keep up-to-date customer due diligence information in the required manner.