The JFSC have issued a Public Statement on Ms Gisele Helene Le Miere (Ms Le Miere) stating she LACKED INTEGRITY AND COMPETENCE ALONG WITH ALL RELATED PARTIES on a film investment opportunity. Ms Le Miere was the Managing Director and Money Laundering Reporting Officer of Jordans Trust Company (Jersey) Limited (JJL) from 2004 to 2014. Ms Le Miere resigned from JJL in July 2014. JJL was authorized by the JFSC to conduct trust company business as defined in the FS(J)L.

THE JFSCs key findings

Following a complaint the JFCS investigated Ms Le Miere behaviour and sought evidence to her actions, unfortunately this was not found as shown below.

1. Material information regarding parties connected to the film investment opportunity WAS NOT APPROPRIATELY DISSEMINATED BY MS LE MIERE TO EITHER THE JJL BOARD OF DIRECTORS OR THE COMPLIANCE COMMITTEE, despite several opportunities for her to do so.
2. Further, Ms Le Miere either DID NOT RECOGNIZE OR DID NOT ACT TO REMEDY INACCURATE INFORMATION provided to the JJL Board of Directors and, also, the Compliance Committee on several occasions concerning the film investment opportunity.
3. Ms Le Miere FAILED TO IDENTIFY ADEQUATELY AND CONSIDER THE RISKS ASSOCIATED WITH TAKING ON THE CUSTOMER RELATIONSHIP for the film investment opportunity and related parties at the outset and when presented with changing circumstances throughout the dealings with the parties.
4. Where risks were identified or understood by Ms Le Miere, SHE FAILED TO ADEQUATELY DOCUMENT THE RISK ON JJL’S RECORDS.
5. Ms Le Miere PLACED OVER-RELIANCE ON THE EXTERNAL ASSOCIATE to assist with the management of, and communication with, the various third parties regarding matters relating to the film investment opportunity.
   1. THE EXTERNAL ASSOCIATE WAS NOT FORMALLY ENGAGED BY JJL, and the scope of the arrangement was unclear and undocumented.
   2. THE EXTERNAL ASSOCIATE HAD CONFLICTS OF INTEREST on THE FILM INVESTMENT OPPORTUNITY, which was neither properly considered nor understood by Ms Le Miere nor documented at all by her on JJL’s records.
   3. Ms Le Miere DID NOT MAINTAIN ADEQUATE RECORDS OF IMPORTANT MEETINGS AND/OR DISCUSSIONS which took place concerning the relationship. Indeed, in many instances, there was a TOTAL ABSENCE OF DOCUMENTARY RECORDS about MEETINGS/DISCUSSIONS.
6. Further, Ms Le Miere was UNABLE TO EVIDENCE THE RATIONALE FOR SIGNIFICANT DECISIONS she made and courses of action undertaken at her behest about the film investment opportunity.
7. THE MAJORITY OF THE DOCUMENTATION WAS INADEQUATE – this information being information obtained/prepared by Ms Le Miere, and/or junior staff under her direct supervision, in connection with the relationship.

Conclusion

1. Do not take short cuts and record, record and record and verify your documentation, particularly:-
   1. Communications
   2. Conflicts
   3. Exceptions
   4. Meetings
   5. Decisions
   6. Risk assessments

Read the statement – http://bit.ly/2kWCPJF