Public Statement relating to Settlement Agreement between Central Bank of Ireland and Appian Asset Management Limited

• Date: 15 June 2018

1

Settlement Agreement between the Central Bank of Ireland

and

Appian Asset Management Limited

The Central Bank of Ireland imposes a fine of €443,000 on Appian Asset Management

Limited for regulatory breaches causing the loss of client funds

On 13 June 2018, the Central Bank of Ireland (the “Central Bank”) fined Appian Asset

Management (“Appian” or the “Firm”) €443,000 and reprimanded it for significant breaches

across three regulatory regimes: client asset, anti-money laundering, and fitness and probity.

The breaches have been admitted by the Firm.

The Firm’s historic regulatory failures left it exposed to a cyber-fraud by a third party where,

acting on the instructions of a fraudster impersonating a client, it facilitated a series of

transactions resulting in the loss of €650,000 of a client’s funds. The client was fully

reimbursed.

The Central Bank had regard to section 33AS(1) of the Central Bank Act 1942, and had it not

been for the financial position of the Firm, the Central Bank would have imposed a financial

penalty of €825,000.

The Central Bank’s enforcement investigation identified that the loss of client funds was

caused by Appian’s failures in the following areas:

(i) it had defective controls to protect client assets against fraud;

(ii) it had inadequate policies and procedures to monitor transactions, detect and

report money laundering and provide its staff with appropriate training; and