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A Guernsey financial consultant has been fined £210,000 and banned from working in the industry after an investigation found that she had knowingly worked for an alleged war criminal.
An investigation was launched into Ginette Louise Blondel by the Guernsey Financial Services Commission in September 2021.
The Commission subsequently found that Ms Blondel breached various regulations and she was issued a fine and prohibition order this month.
Express took a closer look at the case...
In a public statement, the GFSC explained that Ms Blondel is a Guernsey resident who worked in regulated financial services for 13 years. She has an MSc in Corporate Governance and is an Associate of the Chartered Governance Institute.
After leaving the regulated industry she began working for a client as his son’s personal assistant. This employment was confirmed via an official agreement made in 2014 between Ms Blondel and a company the client owned.
This consultancy role would see her advise and assist the client with business and administration.
Subsequently, Ms Blondel started working informally for a second client in 2014.
In a public statement the GFSC refers only to the two relevant clients as Client 1 and Client 2.
Pictured: The GFSC is the island's regulatory body for the finance sector.
Client 1 is a politically exposed person (PEP) who has been under investigation for money laundering.
He is also an alleged war criminal and kleptocrat, with the GFSC indicating that “there were several credible adverse media articles on Client 1, which Ms Blondel was fully aware of”.
He had been a major client of Ms Blondel’s while she had been working as a Trust Manager in Guernsey.
When she left her employment in Guernsey Client 1’s company structures were migrated to a Corporate Service Provider outside the Bailiwick and Ms Blondel joined the operation in 2013.
This individual was ultimately convicted of organised money laundering of state funds of a high-risk country and aggravated tax fraud.
Ms Blondel was introduced to Client 2’s family office in 2014.
The family were comprised again of 'politically exposed persons'.
They were again noted as being high risk, as various media reports had alleged the family had been involved in a “monopolistic business empire” had “close ties with the ruling family of the jurisdiction they were in” and had been “allegedly involved in corrupt practices”.
“Ms Blondel was therefore aware of the very high-risk nature of this client family, and the risks she was taking on in providing services to them,” said the GFSC.
Ms Blondel accepted two directorships for Client 1’s entities in 2013 and went on to hold a total of 11 directorships.
The Commission found that Ms Blondel’s role went beyond that of a personal assistant and involved consultation, advice on the transference of entities out of Guernsey, and further advice on loan positions. These all constituted regulated activities under the Fiduciaries Law.
She also used a personal bank account to facilitate payments on behalf of Client 1.
The Commission said “these payments led to a very real risk that Ms Blondel may have been used to launder the proceeds of crime, a risk which Ms Blondel has consistently failed to recognise”.
Ms Blondel also took on Company Secretarial positions for Client 2 and entered into a consulting agreement with them.
“Ms Blondel’s actions demonstrate that, despite her extensive trust and company administration experience, she was not aware of her legal and regulatory obligations and demonstrated a lack of soundness of judgement allowing significant breaches to occur,” continued the Commission.
Ms Blondel was found to have carried out dozens of activities that should’ve been covered by a licence under the Fiduciaries Law – and even with a licence she shouldn’t have undertaken any trust and corporate administration duties as she is an individual and not a Bailiwick body.
Additionally, she was found to not have any Anti-Money Laundering procedures in place, and there were no formal risk assessments conducted on the two clients. This constituted a breach of financial regulations. She was also in breach of the Company Director Code.
The Commission said that Ms Blondel consistently failed to understand the gravity of her actions.
In its statement the GFSC said: “Ms Blondel continued to provide services (for which she was remunerated until March 2020) for Client 1 and their family when she knew that Client 1, was under investigation for money laundering and was an alleged war criminal and kleptocrat.
“Ms Blondel was aware of the regulated fiduciary regime. She also received legal advice which advised on several aspects of regulated activities. Despite this, she materially contravened the requirements of the Fiduciaries Law.
“Given the high-risk nature of the clients she serviced, in particular in relation to Client 1 (who was ultimately convicted of organised money laundering of state funds of a high-risk country and aggravated tax fraud), Ms Blondel caused, (due to a media article naming Guernsey), reputational damage the Bailiwick as an International Finance Centre.”
Ms Blondel cooperated with the GFSC’s investigation and settled early in the process.
The Commission's decision was as follows:
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