Enforcement Process

The Compliance Monitoring Committee

The Compliance Monitoring Committee (the CMC) is an internal organ set-up by the FIAU to assist in the exercise of its enforcement powers. It is tasked with the onerous responsibility of determining breaches of AML/CFT obligations and establishing the most appropriate administrative measures to be imposed in response to the breaches identified. This is decided depending on the severity and materiality of the breaches identified and in line with the FIAU’s internal policies, namely the sanctions policy and the CMC governing principles. The CMC is chaired by the FIAU Director, or in their absence, the FIAU Deputy Director, and its other members comprise of the Head of the Enforcement Section and senior representatives from the Enforcement and Legal Affairs Sections of the FIAU.

Enforcement Process:

Where a potential breach of the subject person’s AML/CFT obligations is identified, a potential breaches letter is issued by the FIAU and sent to the SP outlining such potential failures. The subject person then has the opportunity to submit both written and oral representations. The case is then referred to the Enforcement section for review and assessment and presented to the CMC for final determination. The outcome of the case is then communicated to the subject person, this including any corrective action required to be undertaken.

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