It is necessary to ensure members comply with the Institute’s Charter, Bye-Laws and Regulations (including the
Code of Conduct) through the Institute’s disciplinary process. The application and administration of the
disciplinary process shall be overseen and directed by the Disciplinary Committee.
Chartered FCSI 22 January 2021
A Chartered Fellow notified the CISI that they had been subject to disciplinary action by their employer for breaching its personal dealing policy. The CISI’s Disciplinary Panel found that they had contravened principles contained within the CISI Code of Conduct and committed a disciplinary offence under the CISI Membership Regulations:
“16.1 (d) if a member has committed any breach of these Regulations (including the Regulations of professional conduct at paragraph 3 of the Regulations) or of any provision of the Institute’s Charter, Bye-Laws and General Regulations or any other Regulations made thereunder.”
The member received a severe reprimand from the CISI. This will remain on their record for six months during which time their Chartered status will be suspended.
Mr Kevin Gilligan ACSI 10 June 2020
We discovered that Mr Gilligan had been personally sanctioned by the Guernsey Financial Services Commission and prohibited from performing the functions of director, controller, partner or manager of a regulated entity for six years and two months. The Commission’s investigation found that a regulated firm, of which Mr Gilligan was a director, failed to (1) administer certain funds in accordance with the principal documents and information particulars, (2) abide at times with contractual and legal obligations, (3) adequately identify and manage conflicts of interest, (4) obtain adequate client due diligence and enhanced due diligence in relation to its book of business, (5) at times effectively monitor business relationships and transactions, (6) at times, to ensure that proper books and records were kept and that these were readily retrievable and (7) at times, to exercise effective policies procedures and controls for forestalling, preventing and detecting money laundering and terrorist financing. It also found that the directors failed, at times, to adhere to a director’s fiduciary duty to act in the best interest of a company.
Mr Gilligan was found to have breached the disciplinary offences 16.1 (a), 16.1 (b) and 16.1 (d) as per the CISI Membership Regulations, including several Code of Conduct principles.
Mr Gilligan has been expelled from CISI membership for a period of six years and two months.
16 April 2020
A Chartered Fellow notified the CISI that they had been subject to disciplinary action by their employer and was
to appear before a Disciplinary Panel on 1st April 2020. The member was found to be in contravention of several
principles within the CISI Code of Conduct, including the upholding of personal and professional standards at all
The Disciplinary Panel also found the member to be in breach of the following disciplinary offences in the CISI
16.1(a) if, whether in the course of work (within the financial services industry or other
industries) or in the course
of his/her personal life or otherwise, a member has committed any act or default likely to bring discredit to
himself/herself, the Institute or the securities, investment, wealth and financial planning profession.”
16.1 (d) if a member has committed any breach of these Regulations (including the Regulations
of professional conduct at
paragraph 3 of the Regulations) or of any provision of the Institute’s Charter, Bye-Laws and General Regulations
other Regulations made thereunder.”
The member received a severe reprimand that will remain on their record for a 6-months, during which time their
Chartered status will also be suspended. The member must also complete the CISI’s IntegrityMatters test within 6
Daniel Coleman, Chartered FCSI
11 December 2019
Mr Coleman notified that he had been subject to disciplinary action by his employer and was invited to appear before
a Disciplinary Panel. After the Panel considered the matter and submissions, they found him in breach of the CISI
Membership Regulations and Code of Conduct. Mr Coleman received a suspension of Chartered status for a period of 18
months, only being permitted to use FCSI designatory letters during this time and required to complete an additional
five hours of CPD, within a six-month period.