The Financial Markets Tribunal (FMT) has upheld enforcement action taken by the Dubai Financial Services Authority (DFSA) against Gilles Rollet for “serious misconduct”.
The tribunal ordered Rollet to pay half of the DFSA’s costs after he appealed a fine and ban handed to him by the Dubai regulator in November 2021.
On 12 January 2022, the FMT issued its decision upholding the DFSA’s findings and imposing the following sanctions:
- A fine of $175,000 (£128,092, €151,267);
- A prohibition from holding office in or being an employee of certain DFSA-regulated entities; and
- A restriction from performing any function in connection with the provision of financial services in or from the Dubai International Financial Centre (DIFC).
Rollet was senior executive director at DIFC-based La Tresorerie, a provider of advisory, discretionary, execution-only and custodian services for high net worth individuals, family offices and independent asset managers.
This comes almost two years after the Dubai regulator fined now-liquidated La Tresorerie for illegal activities, which included transferring client money to unregulated companies outside of the DIFC.
Findings
In November 2021, the DFSA said that Rollet, who was also licensed director of the firm, breached regulatory guidelines due to “his knowing involvement in La Tresorerie unlawfully providing physical cash to its clients”.
The unlawful cash service operated between February 2015 and January 2017 and involved “the use of false invoices and transferring client money to unregulated companies outside the DIFC; and “the occasional transportation of physical cash from the UAE to a foreign country”.
In the January 2022 tribunal, the FMT said it imposed the sanctions on Rollet because it found that he:
- Was knowingly involved in the wrongdoing arising from La Tresorerie’s provision of the unlawful cash service, as described above;
- Failed to act with integrity;
- Failed to ensure that La Tresorerie’s business was organised so that it could be managed and controlled effectively and to ensure that it complied with DIFC legislation; and
- Provided false and misleading information to the DFSA about his involvement in the unlawful cash service.
A spokersperson for the FMT said: “Rollet, a senior banker, did not need compliance training to know full well that these cash schemes were obviously improper and a potential vehicle for serious crime. This was a brazen disregard of important principles by a senior executive.
“The financial system only works if its key players are fit and proper and Rollet demonstrated to us that in these matters he was neither. There has been no recognition by Rollet of the seriousness of these matters.”
Integrity
F Christopher Calabia, chief executive of the DFSA, said: “The DFSA continues to place a high priority on holding to account senior individuals who are at the centre of wrongdoing by firms.
“As the FMT has pointed out, a senior executive officer should be particularly watchful about all matters of regulation, including smaller but high-risk areas of their business. As an experienced financial services professional, Rollet was well aware of compliance matters and, in particular, the risks of dealing with physical cash.
“The unlawful cash service created client money and financial crime risks that were as obvious as they were unacceptable. Any individual who displays such lack of integrity has no place in financial services in the DIFC.”
