Corporate News

Conclusion of Gibraltar regulated entities Skilled Person Review

11 June 2018

STM, the cross border financial services group is pleased to announce the conclusion of the third party review (the "Report") being carried out by Deloitte LLP for certain STM Gibraltar regulated businesses (the "Companies") and the Gibraltar Financial Services Commission ("GFSC") under Section 7 of the Financial Services (Information Gathering and Co-operation) Act 2013 pursuant to the update provided on 1 June 2018.

As previously announced the agreed scope covered, inter alia, the effectiveness and oversight of the Companies' internal compliance function which is a central service for all the Gibraltar subsidiaries, corporate governance and controls, and an assessment of any potential conflicts of interest arising across the business. In addition, the review also covered certain specific areas in relation to the pensions and life assurance business relating to take-on and monitoring procedures for intermediaries, clients and investments advised by intermediaries.

The Report identified 32 findings across the Companies. This includes seven highlighted as priority where improvements are required to ensure that the businesses comply with the relevant Gibraltarian legislation and best practice and twenty one other findings with recommendations that will help improve the governance and compliance framework of the business. The Report noted that a significant part of the legislation which applies is principle based.

The Report puts forward a number of recommendations in relation to governance, including a more embedded risk framework with better defined risk appetite statements and additional non-executive directors for the relevant subsidiary boards. Specifically in relation to the life assurance company the Financial Services (Insurance Companies) (Solvency II Directive) Act 2015 has required since 1 January 2016 an internal audit function, which we are pleased to say has now been put in place.

The Report stated that the Companies should strengthen their Gibraltar Compliance Plan. A plan has already been submitted to the GFSC, with more detail as to how monitoring and oversight will be carried out in future, including a rolling review of intermediaries and clients. The Report provides a number of recommendations in this respect including segregation for first line and second line of defense. The Report also identified that there should be a more robust framework in place for identifying and recording how potential conflicts of interest across the businesses should be dealt with.

The Report acknowledges that some recommendations have already been implemented outside of the review period. The appointment of a Group Head of Enterprise Risk Management in March 2017, following a decision to recruit in mid-2016, has already strengthened the overall governance and compliance framework of the overall Group and thus benefitting underlying subsidiaries.

STM welcomes the recommendations put forward in the Report by Deloitte (the "Recommendations"), and the Companies now expect to engage with the GFSC in order to discuss the Recommendations and agree a plan of action to implement them. The Recommendations will make the Group's businesses more robust and the Board believes their implementation will ensure that the Companies continue the improvement of the processes and systems that they use to conduct their activities in line with the requirements of the GFSC.


For further information, please contact:

STM Group Plc
Alan Kentish, Chief Executive Officer Via Walbrook PR
Therese Neish, Chief Financial Officer
Matt Goode / Emily Watts - Corporate Finance Tel: +44 (0) 20 7220 0500
Tim Redfern / Richard Chambers - Corporate Broking
Tom Cooper / Paul Vann Tel: +44 (0) 20 7933 8780
Mob: +44 (0) 797 122 1972
[email protected]


Notes to editors:

STM is a multi jurisdictional financial services group which is listed on the AIM Market of the London Stock Exchange. The Group specialises in the delivery of a wide range of financial service products to professional intermediaries and the administration of assets for international clients in relation to retirement, estate and succession planning and wealth structuring.

Today, STM has operations in the UK, Gibraltar, Malta, Jersey and Spain. The Group is looking to expand through the development of additional products and services that its ever more sophisticated clients demand. STM has developed a specialist international pensions division which specialises in Qualifying Recognised Overseas Pension Schemes (QROPS), Qualifying Non UK Pension Schemes (QNUPS). STM also has two Gibraltar Life Assurance Companies which provide life insurance bonds - wrappers in which a variety of investments, including investment funds, can be held.

Further information on STM Group can be found at


Options UK 
(part of STM Group Plc)
1st Floor Lakeside House
Shirwell Crescent
Furzton Lake
Milton Keynes


London & Colonial Services Limited
(part of STM Group Plc)
1st floor
21 Perrymount Road
Haywards Heath
West Sussex
RH16 3TP


PO Box 575
Montagu Pavilion
8-10 Queensway
GX11 1AA


San Gwakkin Building
Level 1
Triq is-Salib tal-Imriehel
Zone 4
Central Business District
Birkirkara, CBD4020


Edif. Sotovila
Plaza Mayor
P.N. de Guadiaro


Suite 315
5 Chancery Lane
London,EC4A 1BL


1st Floor,
Viking House,
St Paul’s Square, Ramsey,
Isle of Man,
IM8 1GB.

STM is a multi-jurisdictional financial services group listed on AIM, a market operated by the London Stock Exchange.
The Group specialises in the administration of client assets in relation to retirement, estate and succession planning and wealth structuring.

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STM Group companies are regulated where required in their host jurisdictions.

STM in the UK (London & Colonial and Options UK): Financial Conduct Authority - STM in Gibraltar: Gibraltar Financial Services Commission - STM in Malta: Malta Financial Services Authority - STM in Spain: Director General de Seguros, Fondos y Pensiones: STM Nummos, SL figura inscrita en el Registro Mercantil de Cádiz, Tomo 1612, Hoja 6697, Libro 0, Folio 14. CIF B-11301199.

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