3 rd Compliance & Anti Money Laundering Seminar Enforcement at the QFC George Pickering,

1. 3rd Compliance & Anti Money Laundering Seminar Enforcement at the QFC George Pickering, Managing Director Policy, Enforcement and Risk Division

2. Overview of Enforcement • Guiding principles • Investigation process • Disciplinary action • Decision-making process and review [see A Guide to Our Approach to Regulation]

3. Guiding principles • Swift and decisive • Operate transparently and accountably • Maintain procedural fairness and integrity • Keeping the QFC financial services community informed • Co-operation with other agencies – domestic and international • Co-operation within the QFC Regulatory Authority

4. Formal appointment of an investigation officer • Wide investigative powers: • Compel persons to attend and answer questions • Compel production of books and records • Require production of reports • Vary or suspend individual approval • Apply to Civil and Commercial Court to assist • Produce written report of investigation Investigation process

5. Impose or vary conditions, restrictions etc on an Authorisation or Approval • Withdraw an Authorisation/Approval or remove a Regulated Activity from a firm’s Authorisation • Public censure • Financial penalty • Appointment of manager • Enforceable undertakings • Directions power – prohibitions and/or requirements • Injunctive relief Disciplinary action

6. Enforcement Committee • QFC Regulatory Authority Board • Notice of proposed action • Representations • Decision Notice • Publicity • QFC Regulatory Tribunal: • Considers appeals against decisions of the Regulatory Authority and other QFC Institutions • 60-day appeal period • QFC Civil and Commercial Court Decision making and appeals