A lack of “robust oversight” and “of documented details of discussions” are the headline findings highlighted in the JFSC’s  Public Statement summarising the fines totalling £719,000 against three SG Kleinwort Hambros firms in Jersey.

A closer review of the statements lists over 30 significant failings identified by the JFSC, that go to the very core of good governance and risk management that boards of any regulated, and indeed unregulated, organisation should be paying close attention to.

The failings are wide ranging and include:

• Lack of overall board oversight of the Compliance and Risk responsibilities, including inadequate risk management systems, evidence of robust discussion of significant compliance matters and a failure to notify the regulators of certain matters requiring notification.

• Significant and material failures because it left the board under informed in terms of Compliance Risk and whether they were operating robust systems and controls to mitigate against financial crimes.

• These include full board oversight, unanswered questions on the adequacy of the resources of the compliance function and its arrangements, management information, and effective compliance monitoring.

The list is endless, and yet based on the information provided at least, many of the shortcomings could have been addressed much earlier and, indeed with good basic governance, could have been avoided entirely.