JFSC’s Exec Director of Enforcement, Intelligence and Financial Crime comments on Garfield Bennett fine
13/08/2025
On 6 August 2025, the JFSC published a statement that on 31 July 2025, the JFSC imposed a civil financial penalty of £86,803.19 on GBTCL under the Commission Law.
Kerry Petulla, the JFSC’s Executive Director of Enforcement, Intelligence and Financial Crime commented:
- “This penalty is levied against GBTCL due to the regulatory breaches identified.
- We consider the Board of GBTCL did not ensure it had relevant experience in JPF’s and it failed to adequately manage conflicts and high-risk factors presented in the funds.
- This exposed Jersey to significant risks of financial crime occurring through Jersey-based structures.
- Failures of this nature have the potential to undermine the integrity and stability of Jersey’s financial services industry.
- We urge all financial services businesses operating in the Island to review the findings identified in the public statement issued today by the JFSC in relation to this case, and to ensure their own compliance with our regulatory framework.
- This case underscores the importance of robust governance, appropriate expertise, and effective risk management in maintaining Jersey’s reputation as a well-regulated international finance centre.”
The Board of GBTCL commented:
- “The Board of GBTCL note that no investors suffered any loss in relation to the Funds concerned.
- Nonetheless, it acknowledges the issues that occurred between 2020 and 2022 as highlighted by the JFSC and has completed remediation of the shortcomings set out in the public statement.
- The business has invested in its systems and controls, and the GBTCL Board has been strengthened.
- The GBTCL Board intends to grow the business and welcomes the opportunity to conclude this matter by way of early settlement.”
Source
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.