Disciplinary Findings
Disciplinary findings will appear on the CISI website for as long as a sanction remains on a member’s record.
The recommended time a sanction should remain on a member’s record is set by the Disciplinary Panel, and is
usually 12 months from the date of the hearing.
A Disciplinary Panel may determine that a member is in breach of the regulations, and impose a sanction, but use
their discretion not to publish the findings. Reasons why a Disciplinary Panel may determine that publication is
inappropriate include (but are not limited to):
- That doing so would harm a third party;
- The member is considered to be, and has provided information to demonstrate, that they are a vulnerable
individual;
- That doing so would prejudice an ongoing investigation into the same/similar matter by another organisation.
It is necessary to ensure members comply with the Institute’s Charter, Bye-Laws and Regulations (including
the
CISI
Code of Conduct) through the Institute’s disciplinary process. The application and administration of the
Institute’s
disciplinary process shall be overseen and directed by the Disciplinary Committee.
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.
Mr Gufur Hussain, formerly Chartered MCSI 16 September 2021
The Jersey Financial Services Commission (the “Commission”) determined that Mr Hussain had failed to
declare
conflicts of interest in dealing with clients, overridden safety measures put in place by the Commission to
protect
a client who had been deemed a ‘vulnerable person’ and on several occasions failed to disclose
certain
information
requested by or due to the Commission. The Commission concluded that Mr Hussain lacks integrity and therefore
banned
him from performing any function for, engaging in any employment with, or holding any position in any business
licensed to conduct financial services in Jersey without the prior written approval of the Commission.
The CISI found Mr Hussain to have breached Clauses 16.1 (a) (as a result of contravening 16.2) and 16.1 (e) of the
CISI Membership Regulations, as well as several CISI Code of Conduct principles.
As a result, Mr Hussain has been permanently expelled from CISI membership and forfeited his Chartered MCSI
designation.
Abiodun Alebiwou, ACSI - 6 April 2022
The Securities and Exchange Commission in Nigeria (SEC) identified a series of failings in relation to Mr
Alebiowu’s
role as a sponsored individual of Amyn Investments Limited (AIL). These included failure to notify the SEC of
unprofessional behaviour and breaches of SEC Rules and Regulations at AIL, and failing to remit the proceeds of
a
sale. As a result, the SEC banned Mr Alebiowu from participating in all capital market activities and holding a
directorship position in any public company in Nigeria for a period of three months from the 10th of November
2020
to the 10th of February 2021.
The CISI found that, due to his professional activities having been found by a regulator to have been capable of
adversely affecting confidence in capital markets, Mr Alebiowu had breached paragraph 16.1 (a) of the CISI Membership
Regulations. Furthermore, due to a penalty having been imposed on him by a regulator, he also
breached
paragraph 16.2 and, because of his delay in notifying the CISI of his investigation and punishment by the SEC,
he
breached paragraph 16.1 (e), with particular focus on the CISI Code of Conduct in relation to Personal
Accountability.
As a result, Mr Alebiowu received a reprimand from the CISI to stay on his membership record for 12 months. In
addition, Mr Alebiowu will be required by the CISI to complete both three additional hours of CPD and the CISI
IntegrityMatters test within six months.
Brett Armitage, formerly Chartered MCSI - 2 May 2022
The Isle of Man Financial Services Authority conducted a supervisory inspection in respect of Bridgewater (IOM)
Limited, that identified contraventions of the Anti-Money Laundering and Countering the Financing of Terrorism
Code 2019 (“the Code”) (“the Contraventions”). The Investigation identified a range of
issues which caused it to
assess the fitness and propriety of the persons undertaking certain controlled functions at Bridgewater (IOM)
Limited. As a result, the Authority concluded that the individuals holding such roles are not fit and proper to
hold the roles at Bridgewater (IOM) Limited and, in certain instances, in the regulated sector in the Isle of
Man and therefore exercised its powers under s.10A of the Act to prohibit those role holders from continuing in
those positions. As a result, Mr Armitage is prohibited from working in the financial services industry in or
from the Isle of Man for five years.
The CISI found that Mr Armitage had breached paragraphs 16.1 (a) and (e), as well as 16.2 (b) of the CISI Membership
Regulations. As such, Mr Armitage has been expelled from CISI membership for 5 years, to run coterminously with
his sanction from the Isle of Man Financial Services Authority and has therefore, forfeited his Chartered MCSI
designation.
Alan Northmore, MCSI (Chartered status suspended) - May 2022
In 2021, the Guernsey Financial Services Commission conducted an investigation that identified that Mr Alan
Northmore had failed to demonstrate that he acted with competence, soundness of judgement and diligence, due to a
number of failings related to a Politically Exposed Person (“PEP”) and not ensuring that the Licensee’s procedures
and controls were appropriate and effective with regard to the Licensee’s high-risk appetite. As a result, the
Guernsey Financial Services Commission imposed a financial penalty of £56,700 on Mr Northmore, under section 39 of
the Enforcement Powers Law.
Following a Panel Hearing, it was found that Mr Northmore had breached paragraphs 16.1 (a) and 16.2 (b) of the CISI Membership Regulations and he has therefore been sanctioned with a reprimand to stay on record for 12 months. During this time, Mr Northmore will also have his Chartered status suspended.