This case involved an appeal to the regulatory tribunal of a decision of the QFCRA which ordered the payment of a penalty and the prohibition of a CEO from working in a controlled function in the QFC. The individual had been a CEO and had held other senior management roles at a firm which had been found guilty of failure to conduct money laundering control activities on two occasions. Key issues included that after an initial investigation remedial steps had not been taken. Issues included the CEO's personal responsibility when matters had been delegated to the MLRO by him and if he had purposefully concealed matters from the regulator by making changes to a report which should have been carried out by an independent reviewer (when the reviewer used was working for the firm in another context.)