CBOI Fines IA for Privacy, AML

On Jun. 15, CBOI fined I/A €443k for exposure to cyber-fraud.


  • Appian Asset Management breached client asset, AML, and fitness, probity rules.

Alleged Violations

  • The firm’s historic regulatory failures left it exposed to cyber-fraud by third party.
  • Acting on instructions of fraudster impersonating client, it facilitated transactions.
  • Over two-month period no one at Appian suspected fraud, AML, terror financing.
  • Mar. 2015, businessperson (real client) invested €1mn in two managed sub-funds.
  • In Apr. 2015, a cyber-fraudster (fake client) hacked real client’s web-based email.
  • Impersonated him in protracted series of email correspondence with an employee.
  • Failure resulted in client losing €650k in funds and has now been fully reimbursed.
  • Firm has remediated its failings, and complied with CBOI Risk Mitigation Program.