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Enforcement Actions in 2022
Disciplinary action against Rudolfs Veiss, former Ultimate Beneficial Owner
(UBO), Director and Executive Governance Function (EGF) of Prime Financial
Solutions LLC (previously known as International Financial Services (Qatar) LLC)
In September 2022, the QFCRA took disciplinary action against the former UBO, Director and EGF of Prime
Financial Solutions LLC (formerly known as International Financial Services (Qatar) LLC), Mr Rudolfs Veiss, for
failing to comply with requirements imposed on the firm by the QFCRA in a Supervisory Notice, for obstructing
the QFCRA’s investigation and for failing to act with integrity, failing to act with due skill, care and diligence and
failing to deal with the QFCRA in an open and cooperative manner by making misrepresentations to the QFCRA.
Mr Veiss appealed the QFCRA’s decision to impose a financial penalty of USD 500,000 and a five-year prohibition
from carrying out any function in the QFC. The QFCRA’s disciplinary action remains subject to an appeal in the
QFC Regulatory Tribunal.
Disciplinary action against Mr Luis Laplana, an investment
manager for two customers of Horizon Crescent Wealth LLC (HCW)
In October 2022, the QFCRA took disciplinary action against an investment manager for two customers of HCW,
Mr Luis Laplana, for providing misleading information to the QFCRA during its investigation of the firm. The QFCRA
imposed a financial penalty of USD 150,000 and an indefinite prohibition from carrying out any function for firms in the
QFC. Mr Laplana did not appeal the decision of the QFCRA, and therefore, the financial penalty is due and payable.
Disciplinary action against Mr Robert Edward Sharratt, Director,
and member of senior management of Horizon Crescent Wealth LLC
In September 2022, the QFCRA took disciplinary action against a former director and member of senior
management of HCW, Mr Robert Edward Sharratt, for failing to ensure the firm’s policies, procedures, systems
and controls (PPSC’s) appropriately and adequately addressed the requirements of the Anti-Money Laundering
Law No. (4) of 2010 and the QFC AML/CFT Rules (AML/CFTR), failing to ensure that HCW developed, established
and maintained effective AML/CFT PPSC, failing to document those policies, failing to at all times have an
experienced and effective Money Laundering Reporting Officer and failing to ensure that Money Laundering
and Terrorist Financing (ML/TF) risks were taken into account in the day-to-day operation of the firm.
The QFCRA imposed on Mr Sharratt a financial penalty of USD 150,000 and an indefinite prohibition from carrying
out any function in the QFC. Mr Sharratt did not appeal the decision of the QFCRA, and therefore, the financial
penalty is due and payable.
T ABLE OF C ONTENT S
Disciplinary action against Mr Patrick Claude Baeriswyl, Director,
and member of senior management of Horizon Crescent Wealth LLC
In September 2022, the QFCRA took disciplinary action against a former director and member of senior
management of HCW, Mr Patrick Claude Baeriswyl, for failing to ensure the firm’s PPSC’s appropriately
and adequately addressed the requirements of the Anti-Money Laundering Law No. (4) of 2010 and the
AML/CFTR, failing to ensure that HCW developed, established and maintained effective AML/CFT PPSC,
failing to document those policies, failing to at all times have an experienced and effective MLRO and
failing to ensure that ML/TF risks were taken into account in the day-to-day operation of the firm.
The QFCRA imposed on Mr Baeriswyl a financial penalty of USD 200,000 and an indefinite prohibition
from carrying out any function in the QFC. Mr Baeriswyl has appealed the QFCRA’s decision in the QFC
Regulatory Tribunal and therefore the disciplinary action remains the subject of an appeal.
Disciplinary action against Mr Jean Marc Mantegani, Director, Money
Laundering Reporting Officer and member of senior management of
Horizon Crescent Wealth LLC
In September 2022, the QFCRA took disciplinary action against a director, MLRO and a member of senior management
of HCW, Mr Jean Marc Mantegani, for failing to ensure that the firm’s PPSC’s appropriately and adequately addressed
the requirements of the Anti-Money Laundering Law No. (4) of 2010 and the AML/CFTR to ensure that the firm
adopted the required risk-based approach to AML/CFT as set out in AML/CFTR, to ensure that the firm’s Customer
Due Diligence was appropriate, failing to ensure that the firm maintained and provided documentary evidence of
its compliance with AML/CFTR, and failing to ensure that the firm developed, established and maintained effective
AML/CFT PPSC’s, failing to document those policies, failing to at all times have an experienced and effective
MLRO, and failing to ensure that ML/TF risks were taken into account in the day-to-day operation of the firm.
The QFCRA imposed on Mr Mantegani a financial penalty of USD 300,000 and an indefinite prohibition
from carrying out any function in the QFC. Mr Mantegani has appealed the QFCRA’s decision in the QFC
Regulatory Tribunal and therefore the disciplinary action remains the subject of an appeal.
QFC court judgments
The QFCRA was party to one (1) proceeding in the Qatar International Court in 2022:
-Nigel Perera v Qatar Financial Centre Regulatory Authority [2022] QIC (A) 6.