Following our August 27 article concerning the €1 million fine imposed on Havilland Bank by Monaco’s financial regulator, the bank has provided News.MC with additional information and clarifications concerning several aspects of the published AMSF decision….
A spokesperson clarified that the €3 million transaction highlighted in our original report did not involve a transfer to the Philippines. According to the bank, a dividend was paid to a shareholder before the same amount was loaned back three days later to the company that had distributed it, with both accounts held at the bank. The Philippines featured only because an accountant providing correspondence and audit reports was based there.
The bank also challenged the description of the client as an “associate of a Russian oligarch”. It says the connection arose from the earlier sale of one of the client’s companies to a Russian group owned by the individual concerned, before applicable asset-freezing measures were introduced. The bank stresses that the AMSF sanctions panel did not establish the alleged association in its final reasoning.
They also clarified the regulator’s findings concerning transaction monitoring. Rather than concluding that the €3 million transaction received no scrutiny, the AMSF found that the bank had not demonstrated that a sufficiently formalised special examination meeting regulatory requirements had been completed.
Finally, the bank says the AMSF decision refers to the director general’s involvement in the approval of one specific €1.2 million transaction, rather than establishing a requirement for the director personally to approve every atypical transaction.
These clarifications are published following the bank’s response to our original report.