The Financial Markets Tribunal (FMT), an echo of the old Financial Services and Markets Tribunal of the United Kingdom, has affirmed a decision by the Dubai Financial Services Authority (DFSA) to fine Ms Anna Waterhouse and restrict her from being involved in providing financial services in or from the Dubai International Financial Centre (DIFC).

Ms Waterhouse was previously the head of compliance for the DIFC branch of Deutsche Bank AG, whose tentacles reached out across the region. She was both the compliance officer and Money Laundering Reporting Officer (MLRO).
 
After a lengthy investigation, the DFSA discovered that Ms Waterhouse had provided it with false information on several occasions between 1 January 2011 and 21 January 2014. The FMT reached a decision that confirmed this on 12 August 2019. She repeatedly told the DFSA that Deutsche’s private wealth management team only referred prospective clients to other offices of Deutsche Bank and did not provide them with any financial services. She did not reverse herself over the coming months, allowing deficiencies in the bank's client take-on and anti-money laundering processes to go unnoticed.   
 
The FMT found that Ms Waterhouse had discovered the true extent of the private wealth management team’s activities by November 2011 at the latest and did nothing to tell the DFSA until late 2013, despite her statutory duty to deal with the DFSA in an open and co-operative and/or give it any information which it might reasonably expect to receive.  

The FMT concluded that Ms Waterhouse lacked integrity and was not a fit and proper person to perform functions in connection with financial services in or from the DIFC. The FMT said in its decision: “It is difficult to overstate the crucial importance to the well-being of financial markets that all those who accept positions as Authorised Individuals act with integrity and deal frankly and openly with the regulator.”  
 
Ms Waterhouse subsequently applied to the DIFC courts for permission to appeal against the FMT’s decision. On 12 December her application was refused and she was ordered to pay the DFSA’s costs in relation to the application for permission to appeal.

The history of this case is a long one. In April 2015, the DFSA published its related action against Deutsch for misleading it and mismanaging its internal governance, systems and controls and its client take-on and anti-money-laundering processes.

On 22 June 2017, the DFSA punished Mr Chetan Parmar (who reported directly to Ms Waterhouse) for providing it with false information. Though the DFSA issued a press release about that, it did not publish Parmar's decision notice while Ms Waterhouse was still struggling with the FMT.
 
The President of the FMT is His Honour David Mackie CBE QC, a former Judge of the English High Court.