In 2022/23 the CISI Disciplinary Review Panel reviewed 66 cases, of which 44%
were also disciplined by their employers, 19% related to driving offenses, 16%
related to other criminal offences and 14% were regulatory sanctions. The
remaining few cases related to credit issues and complaints made against
members. Of all the above cases, 10 were found to be serious enough to be
referred to a Disciplinary Hearing Panel.
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
CISI Member – ACSI October 2023
In November 2022, the member was dismissed from their financial services firm
for gross misconduct in failing to disclose that a client had paid the costs
of their holiday hotel, thereby demonstrating a lack of integrity in breach of
the firm’s polices and standards.
Following a CISI Panel Hearing, where the member made representations, it was
found that the member had breached paragraphs 16.1 (a) and (e) of the CISI
Membership Regulations, as well as 3.1: Personal Accountability and 3.3
Conflicts of Interests of the Code of Conduct. As a result, the member
received a severe reprimand to stay on their record for 12 months and a
suspension from membership for 12 months, during which time they will also be
required to retake and pass the CISI IntegrityMatters test and complete 50% of
their CPD on Integrity and Ethics on their first year of their membership
ACSI – August 2023
In January 2023, a member was convicted of drink driving, which resulted in
them receiving a 14-month disqualification and fines totalling £1,275.
Following a Panel Hearing, it was found that the member had breached
paragraphs 16.1 (a), (e), and 16.2 (a) of the
CISI Membership Regulations, as well as 3.1, Personal Accountability of the
CISI Code of Conduct. As a result, the member has received a reprimand which will remain on their
record for 12 months, during which time, the member is required to retake the
CISI IntegrityMatters test.
CISI Member – MCSI (Chartered status suspended)
In January 2022, the member received a fine due to a drink driving conviction.
The member failed to declare this when renewing their SPS although this was
mitigated shortly afterwards, during their membership renewal process.
Following a CISI Disciplinary Panel Hearing, where the member made
representations, it was found that the member had breached paragraph 16.1 (a)
and (e) and 16.2 (a) of the Membership Regulations with a particular focus on
3.1: Personal Accountability, of the Code of Conduct. As a result, the member
received a severe reprimand to stay on record for 18 months, during which time
their Chartered status will also be suspended. The member is also required to
retake and pass the CISI IntegrityMatters test within 6 months.
Brett Armitage, formerly Chartered MCSI 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
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.
Gufur Hussain, formerly Chartered MCSI 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.
Kevin Gilligan, ACSI June 2020
The CISI 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.