UBS International Life Limited

Background The Central Bank’s Anti-Money Laundering and Counter Terrorist Financing (“AML/CTF”) Supervisory Unit identified these breaches during an inspection of the firm conducted in December 2010. Following this inspection, an examination into these issues was conducted by the Central Bank’s Enforcement Directorate. Sanctions Decision Factors The taking of this case and the sanctions imposed reflect the seriousness with which the Central Bank views breaches of the legislative provisions which are designed to prevent the use of the financial system for the purpose of money laundering and terrorist financing. The Central Bank’s examination identified UBS International Life Limited’s failure to take into account and implement the legislative changes imposed by the CJA 2010, particularly in the areas of instruction on the law, third party reliance requirements and the adoption of adequate written policies and procedures in relation to the identification and reporting of suspicious transactions. The Central Bank takes particularly seriously the fact that the UBS International Life Limited did not demonstrate to the Central Bank that it had provided instruction in the law to its staff until December 2010 or to the majority of its directors until April 2011. In deciding the appropriate sanctions, the Central Bank has also taken into account that: 1. the firm has co-operated fully in the examination process and settled at an early stage in the administrative sanctions procedure; 2. the firm has stated that it takes this matter extremely seriously and is fully committed to ensuring that the firm operates at all times in compliance with its legal and regulatory requirements; and 3.