Since 2005 Comsure has helped clients deploy comprehensive strategies in response to financial service regulation. Regulatory changes in the financial services industry have come with dizzying speed and complexity, often with massive implications for business models and competitive strategies. We work with clients to: address the impact of new regulatory requirements, and we provide insights […]

Bonne année! I hope you all had a nice break. As we enter 2017, it is worth preparing ourselves for more oversight and scrutiny and to start with all practitioners should be aware of the U.K. governments intention to introduce a new corporate TAX EVASION criminal offence, based on the STRICT LIABILITY of the entity […]

Comsure Workshop on Suitability of Investment Advice – Following today’s Comsure workshop “Suitability of Advice” – A Workshop for Wealth Managers, Advisers, Trustees “I would like to thank Adrian Kemp [Managing Director – Brooks Macdonald – Retirement Services] for a well-rounded thought provoking talk. His key message included what should a suitability report cover (as […]

plural kleptocracies :  government by those who seek chiefly status and personal gain at the expense of the governed; also :  a particular government of this kind kleptocrat play \ˈklep-tə-ˌkrat\ noun kleptocratic play \ˌklep-tə-ˈkra-tik\ adjective Corruption that empowers kleptocrats at the expense of citizens is one of the greatest governance, development, and security challenges facing […]

JFSC and Government of Jersey gave a presentation on 6 December on how UN and EU sanctions are implemented in and affect Jersey businesses. Key points that may not always be as prominent as they should be:- The process for suspected sanctions breaches to Minister For External Relations  externalrelations@gov.je The need to obtain a license […]

“In some firms, we found serious deficiencies and required substantial changes to be made. We often found a culture of wanting to do the right thing, but struggling to translate this into effective execution. Common root causes were; weaknesses in governance and longstanding, significant under-investment in resourcing and relevant controls. This often led to; an […]

At lunch yesterday I spoke to a friend about SAFE HARBOURS in Jersey for AML matters. My thought on this important matter was that I was not sure there were formal legal, safe harbours albeit it is important to maintain the principle of providing legal, safe harbour to businesses that follow the guidance? The issue […]

Corporate liability for money laundering – Im asked on numerous occasions under what circumstances can a corporate body itself be subject to criminal liability? From my understanding (as a non-legal practitioner) there are two main types of corporate criminal liability at common law: Vicarious liability. For certain offences, companies can be held criminally liable for […]