During the on-site visit and subsequent investigation, the Commission uncovered a range of failings.
- Richmond not always properly verifying its underlying customers or identifying the risks they posed – particularly regarding high-risk individuals, operating high-risk businesses in high-risk countries;
- The source of wealth or funds was not always properly verified;
- Customer relationships were not always adequately monitored and Richmond, on occasion, failed to address serious issues that arose in a timely manner;
- Adequate customer records were not kept;
- Richmond failed to address shortcomings flagged by the regulator prior to 2016, many of which were repeat issues noted from an on-site visit carried out in June 2013.
The on-site visit by the Guernsey regulator in 2016 came one month after a management buy-out resulted in a new senior management team at the firm.
Then-managing director Mike Good led the buy-out, along with directors Jim Elliott, Paul Gaudion, Alan Jenner, Tony Link and John McKellar.
Good is currently chief finance and operating officer, while Elliott is chief executive.
When contacted by International Adviser, the company declined to comment.
In determining what action to take against Richmond, the Guernsey Commission acknowledged the firm’s efforts to implement an extensive remediation programme from January 2016.
The regulator also recognised the firm had engaged an independent consultant to develop a comprehensive risk mitigation programme to improve its corporate, operational and compliance functions.
At all times, the directors of Richmond co-operated fully, the Commission stated.
A 30% discount was applied to the financial penalty after the firm agreed to settle at an early stage.
On its website, Richmond describes itself as a “Guernsey trust company offering clients a professional, approachable and flexible service in the ever developing international markets”.