AG v LGL Trustees Limited 26-Feb-2021 [2021] JRC 058 (26 February 2021)

AG v LGL Trustees Limited 26-Feb-2021 [2021] JRC 058 (26 February 2021)

LGL failed to implement and apply appropriate and consistent anti-money laundering policies and procedures in relation to a high-risk structure involving Angolan state funds and politically exposed persons, despite numerous red flags and regulatory requirements. The seriousness of the breaches, the risk of facilitating corruption, and the negative impact on Jersey's reputation justified a substantial fine, with reductions for cooperation, guilty plea, and the impact on current shareholders.

Citation
[2021] JRC 058
Parties
Defendant: LGL; Prosecution: Attorney General
Jurisdiction
Jersey
Judgment Date
26 February 2021
Procedural Posture
Criminal / Sentencing Judgment After Guilty Plea
Outcome
LGL fined for breaches of anti-money laundering requirements; no penalty on Count 2; costs order imposed.
Legal Topics
Money Laundering, Corporate Compliance, Financial Services Regulation, Sentencing
Criminal Law Financial Regulation Money Laundering Corporate Compliance Financial Services Regulation Sentencing

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Parties

LGL

Defendant

Attorney General

Prosecution

Procedural Posture

Criminal / Sentencing Judgment After Guilty Plea

Legal Issues

  1. 1 Whether LGL breached Article 37(4) of the Proceeds of Crime (Jersey) Law 1999 by failing to comply with anti-money laundering requirements under the Money Laundering (Jersey) Order
  2. 2 Appropriate penalty for breaches involving high-risk jurisdictions and politically exposed persons

Ratio Decidendi

LGL failed to implement and apply appropriate and consistent anti-money laundering policies and procedures in relation to a high-risk structure involving Angolan state funds and politically exposed persons, despite numerous red flags and regulatory requirements. The seriousness of the breaches, the risk of facilitating corruption, and the negative impact on Jersey's reputation justified a substantial fine, with reductions for cooperation, guilty plea, and the impact on current shareholders.

Court Disposition

LGL fined for breaches of anti-money laundering requirements; no penalty on Count 2; costs order imposed.

Orders

  • Fine of £550,000 under Count 1
  • No penalty under Count 2