The FCA has fined discretionary funding supervisor TJM Partnership Restricted £2 million for “severe monetary crime management failings.”
The agency, primarily based at Previous Bailey within the Metropolis of London, went into liquidation on 6 January.
It was discovered to have made severe errors on cum-ex buying and selling, the shopping for and promoting of shares with dividend funds hooked up.
The FCA mentioned the agency was believed to have executed share trades value a minimum of £79bn.
The TJM Partnership Ltd (FCA No. 498199) was authorised and controlled by the FCA and was established in 2009 as a discretionary funding supervisor. It was a supplier of bespoke buying and selling and funding administration companies to high-net value purchasers, household places of work, corporations and intermediaries.
The FCA fined TJM Partnership £2,038,700 for “failing to make sure it had efficient methods and controls to determine and cut back the chance of economic crime and cash laundering in its enterprise. “
The FCA mentioned immediately that is the third case it has introduced in reference to cum-ex buying and selling and the most important high quality thus far.
The FCA mentioned TJM did not have enough procedures, methods and controls in place to determine and mitigate the chance of it getting used to facilitate fraudulent buying and selling and cash laundering in relation to buying and selling on behalf of purchasers of the Solo Group between January 2014 and November 2015.
TJM additionally did not “adequately apply” its anti-money laundering insurance policies and didn’t correctly assess, monitor and mitigate the chance of economic crime.
Buying and selling executed by TJM on behalf of the Solo Group’s purchasers all through the interval was characterised by a round sample of purported trades – traits that are extremely suggestive of economic crime, the FCA mentioned. The buying and selling seems to have been carried out to permit the arranging of withholding tax reclaims in Denmark and Belgium.
TJM executed buying and selling to the worth of roughly £59 billion in Danish equities and £20 billion in Belgian equities and acquired fee of £1.4 million, a big proportion of the agency’s income within the interval.
The agency additionally did not determine or escalate any potential monetary crime considerations and cash laundering dangers in two different situations associated to Solo Group enterprise. This concerned transactions with no obvious financial function besides to switch substantial windfall income of £3.65m amongst its purchasers. TJM additionally accepted cost from a 3rd occasion with out acceptable due diligence.
The investigation course of concerned regulation enforcement companies and regulatory companions around the globe, the FCA mentioned.
Mark Steward, govt director of enforcement and market oversight, mentioned: ‘TJM allowed itself to turn into concerned in a self-evidently suspicious scheme of round transactions that regarded like shams. TJM demonstrated an entire lack of care and diligence in collaborating in these transactions of doubtful function.”