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

Date15 June 2018
Settlement Agreement between the Central Bank of Ireland
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
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

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