ADM Investor Services International Limited (ADMISI) faced significant money laundering risk due to its business model, customer base, geographical location, and involvement with Politically Exposed Persons (PEPs). In 2014, the Financial Conduct Authority (FCA) expressed concerns regarding ADMISI’s anti-money laundering (AML) systems and requested improvements.
Despite these warnings, the FCA found substantial shortcomings during a 2016 firm visit:
- ADMISI’s AML customer risk assessment was basic and did not adequately evaluate a customer’s financial crime risk.
- The firm lacked a comprehensive firm-wide money laundering risk assessment.
- Inadequate ongoing monitoring through periodic customer reviews was evident.
- The firm’s policies were outdated and referenced old legislation.
Following the 2016 visit, ADMISI agreed to specific requirements, such as refraining from engaging with high-risk customers to mitigate money laundering and financial crime risks. By October 2016, ADMISI had implemented AML policies and procedures to address identified concerns. After further remedial actions, the requirements were lifted in January 2018.
ADMISI did not contest the FCA’s findings and requested the Regulatory Decisions Committee to determine the appropriate penalty level under the FCA’s partly contested case process. The firm’s acceptance of the FCA’s findings qualified it for a 30% settlement discount. Otherwise, a financial penalty of £9,243,738 would have been imposed by the FCA.
By FCCT Editorial Team
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