CmaBoardReleases
Title: Announcement regarding issuance of Disciplinary Board Resolution No. (09/2022 Disciplinary Board) (36/2021 Authority) and the imposition of a fine against each of: 1. Al-Madina for Finance and Investment Company, 2. Mr. Emad Al-Deen Fahmi Assaf – Chief Executive Officer of Al-Madina for Finance and Investment Company, 3. Mr. Mohamed Darweish AlShamali – Former Vice Chairman of the Board of Directors of Al-Madina for Finance and Investment Company, 4. Mr. Ahmad Dawud Salman AlSabah – Member of the Board of Directors of Al-Madina for Finance and Investment Company, 5. Mr. Ahmad Abdul-Fattah Bayomi Bader – Former Member of the Board of Directors of Al-Madina for Finance and Investment Company, 6. Ms. Manal Abdul-Kareem Jassem Bin Bader – former Member of the Board of Directors of Al-Madina for Finance and Investment Company, 7. Mr. Emad Hussain Neama – Member of the Board of Directors of Al-Madina for Finance and Investment Company, 8. Mr. Aref Abdullah Musheet Al-Ajmi – Member of the Board of Directors of Al-Madina for Finance and Investment Company, 9. Mr. Mohammad Ali Reda – Portfolio Manager of Al-Madina for Finance and Investment Company, 10. Mr. Mustafa Mohammad Ajami Abdul-Baqi Khaleefa – Risk Manager of Al-Madina for Finance and Investment Company, 11. Mr. Islam Mohammad Wasfi Abdul-Rahman – Compliance Officer of Al-Madina for Finance and Investment Company, 12. Mr. Mohammad Abdul-Kareem Khashab – Financial Manager of Al-Madina for Finance and Investment Company, 13. Mr. Yousef Mousa Abdullah Al-Abdulrazzaq – Former Chief Executive Officer of Al-Madina for Finance and Investment Company for violating the rules of Clients’ Funds and Clients’ Assets, Corporate Governance, and Conduct of Business
Announcement regarding issuance of Disciplinary Board Resolution No. (09/2022 Disciplinary Board) (36/2021 Authority) and the imposition of a fine against each of:
1. Al-Madina for Finance and Investment Company
2. Mr. Emad Al-Deen Fahmi Assaf – Chief Executive Officer of Al-Madina for Finance and Investment Company
3. Mr. Mohamed Darweish AlShamali – Former Vice Chairman of the Board of Directors of Al-Madina for Finance and Investment Company
4. Mr. Ahmad Dawud Salman AlSabah – Member of the Board of Directors of Al-Madina for Finance and Investment Company
5. Mr. Ahmad Abdul-Fattah Bayomi Bader – Former Member of the Board of Directors of Al-Madina for Finance and Investment Company
6. Ms. Manal Abdul-Kareem Jassem Bin Bader – former Member of the Board of Directors of Al-Madina for Finance and Investment Company
7. Mr. Emad Hussain Neama – Member of the Board of Directors of Al-Madina for Finance and Investment Company
8. Mr. Aref Abdullah Musheet Al-Ajmi – Member of the Board of Directors of Al-Madina for Finance and Investment Company
9. Mr. Mohammad Ali Reda – Portfolio Manager of Al-Madina for Finance and Investment Company
10. Mr. Mustafa Mohammad Ajami Abdul-Baqi Khaleefa – Risk Manager of Al-Madina for Finance and Investment Company
11. Mr. Islam Mohammad Wasfi Abdul-Rahman – Compliance Officer of Al-Madina for Finance and Investment Company
12. Mr. Mohammad Abdul-Kareem Khashab – Financial Manager of Al-Madina for Finance and Investment Company
13. Mr. Yousef Mousa Abdullah Al-Abdulrazzaq – Former Chief Executive Officer of Al-Madina for Finance and Investment Company
For violating the rules of Clients’ Funds and Clients’ Assets, Corporate Governance, and Conduct of Business.
For the following reasons:
1) Al-Madina for Finance and Investment Company violated the following:
First: Provision of Item (3) of Article (66) of Law No. 7 of 2010 and its amendments and Article (4-1-2) of Module Seven (Clients’ Funds and Clients’ Assets) of the Executive Bylaws of the mentioned Law:
It was proven to the Authority in a strict manner that the Company deposited the amounts transferred from Dubai related to Tabat Alkheir Company into its own account and not the bank account of the clients which is considered an incorrect procedure in terms of financial transfers.
Second: Provision of Article (68) of Law No. 7 of 2010 and its amendments:
It was proven to the Authority in a strict manner unavailability of the ownership documents of the land located in Jeddah in the Kingdom of Saudi Arabia as a result of the Company’s investment in an associate company (Sarh Capital Real Estate Company) of a real estate in the amount of 15,234,114 KWD without having an ownership document that proves that its associate company owns the mentioned real estate in spite of having registered it in its financial statements of several periods which is considered a violation of Article (68) previously mentioned.
Third: Provision of Item (3) of Article (126) of Law No. 7 of 2010 and its amendments:
It was proven to the Authority in a strict manner that the Company did not provide the inspection team with a number of documents as follows:
a. All of its bank statements and the bank statements of a number of its subsidiaries and their subsidiaries in accordance with the Company’s letter dated 6/12/2020 on the pretext of the bank’s refusal to provide it with those statements because it hasn’t updated its data, and statement of the companies that it failed to provide the inspection team with its bank statements.
b. Full bank statements of a number of its subsidiaries and their subsidiaries without giving any reasons as follows:
• Arabian Pen Company.
• Al-Tatweer Capital Real Estate Company.
• Al-Sanabel Company.
• Economic Pen Company.
• Develop General Trading and Contracting Company.
Full bank statements for the period from 01/01/2018 to 15/11/2020.
Fourth: Provision of Item (3) of Article (127) of Law No. 7 of 2010 and its amendments:
The following was proven to the Authority in a strict manner:
a) The existence of salary transfers from subsidiaries to Al-Madina for Finance and Investment Company or from its associate companies, and when the Company was asked for the reasons behind the subsidiary or the associate company’s paying for the salaries of the employees of Al-Madina for Finance and Investment Company, it answered in a letter dated 30/11/2020 that “the reason behind not paying the salaries of the Company’s employees directly from the bank accounts of Al-Madina for Finance and Investment Company is having an executive attachment on the Company’s accounts by parties with which the Company has legal issues , and reserving the amounts allocated for the employees’ salaries by the bank and not transferring them to the Company’s employees might be expected.”
This is because Al-Madina for Finance and Investment Company has made financial transfers to Develop General Trading and Contracting Company (subsidiary) in accordance with written instructions to pay the salaries of the subsidiary’s employees, which indicates that the claims of Al-Madina for Finance and Investment Company regarding having an executive reservation on its accounts were incorrect and that it has paid the salaries of its subsidiary’s employees at the same time.
b) 44,000 KWD was transferred from AAN Digital Services Holding Company on 09/11/2020 to Real Capital Company. The Company reported to the inspection team that the purpose of this transaction is to transfer from an associate company, noting that pursuant to the structure submitted to the team by the Company as on 30/09/2020, AAN Digital Services Holding Company did not appear to be an associate company to Al-Madina for Finance and Investment Company.
Fifth: Provision of Items (6,8) of Article (5-1-1) of Module Seven (Clients’ Funds and Clients’ Assets) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that the Company did not update some data of several clients of the portfolios managed by it.
Sixth: Provision of Article (5-1-8) of Module Seven (Clients’ Funds and Clients’ Assets) of the Executive Bylaws of Law No. 7 of 2010 and their amendments and Article (1-2) of Module Eight (Conduct of Business) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that Mr. Ahmad Dawud Salman AlSabah – Member of the Board of Directors of Al-Madina for Finance and Investment Company – has opened a portfolio for White Diamond Company for Sale & Purchase of Real Estate at Al-Madina for Finance and Investment Company (portfolio managed by the company) on 28/10/2020, and transferred the assets of White Diamond Company for Sale & Purchase of Real Estate represented by the shares of Al-Bareeq Holding Company (85,610,000 shares equivalent to 29% of Al-Bareeq Holding Company’s total shares) to that portfolio. The mentioned gentleman used the power of attorney granted to him by Ms. Mayada Al-Ali (former Vice Chairman of the Board of Directors of Fiduciary Soft Systems Company and owner of First Traders Real Estate Company “White Diamond Company is a subsidiary of Fiduciary Soft Systems Company”), noting that the Ministry of Commerce and Industry has cancelled the transaction of the transfer of ownership of First Traders Real Estate Company on 03/11/2020 as a result of legal faults included in its procedures. In spite of the existence of an email directed to Al-Madina for Finance and Investment Company (portfolio manager) regarding the complaint of the parent company (Fiduciary Soft Systems Company) of White Diamond Company dated 04/11/2020 in which Al-Madina for Finance and Investment Company was told “not take any instructions from the former manager of White Diamond Company (Mr. Ahmad AlSabah) because his power of attorney was through invalid authority, and that the transaction was cancelled by the Ministry of Commerce and Industry”; however, Al-Madina for Finance and Investment Company has executed the request issued by Mr. Ahmad Dawud Salman AlSabah to sell a number of the shares available into the portfolio of White Diamond Company on 09/11/2020.
Seventh: Provision of Item (11) of Article (5-1-9) of Module Seven (Clients’ Funds and Clients’ Assets) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that the contracts of establishing investment portfolios concluded with its clients did not include a proof of the Company and the client’s compliance with Law No. 7 of 2010 Regarding the Establishment of the Capital Markets Authority and Regulating Securities Activities and its Executive Bylaws and their amendments.
Eighth: Provision of Item (3) of Article (6-5) of Module Eight (Conduct of Business) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that the Company did not record telephone conversations or maintain electronic correspondences for one of the orders sent by the Company to the agent to execute one of the transactions.
Ninth: Provision of Article (9-1) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments in addition to the Company’s noncompliance with Article (9-3) of the mentioned Module:
It was proven to the Authority in a strict manner that the Company did not take any procedure to protect its funds and its shareholders’ funds concerning its subsidiaries’ payment of salaries and the payments related to associate companies or other parties in accordance with verbal instructions which may cause legal risks for those companies in the future (in terms of complying with the authorizations), in addition to representing financial risks (due to unavailability of written instructions).
Tenth: Provision of Article (11-4) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that the Company did not put in place and approve systems and mechanisms to evaluate the performance of each member of the Board of Directors.
Eleventh: Provision of Articles (3-40) and (4-6) of Module Sixteen (Anti-Money Laundering and Combating Financing or Terrorism) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
The following was proven to the Authority in a strict manner:
a. The Company did not obtain adequate information on the purpose and nature of the transactions and maintain records on the domestic and international transactions.
b. The Company conducted or received financial transfers without knowing the account number of the transferring or receiving account.
2) Mr. Emad Al-Deen Fahmi Assaf – Chief Executive Officer of Al-Madina for Finance and Investment Company – violated the following:
First: Provision of Item (3) of Article (66) of Law No. 7 of 2010 and its amendments, and Article (4-1-2) of Module Seven (Clients’ Funds and Clients Assets) of the Executive Bylaws of the mentioned Law:
As for the financial transfers, it was proven to the Authority in a strict manner that he, in his capacity as the CEO of Al-Madina for Finance and Investment Company, deposited the client’s funds in the Company’s accounts as a result of depositing the amounts transferred from Dubai of Tabat Alkheir Company in its own bank account and not the bank account of the clients.
Second: Provision of Article (68) of Law No. 7 of 2010 and its amendments:
It was proven to the Authority in a strict manner unavailability of the ownership documents of the land located in Jeddah in the Kingdom of Saudi Arabia as a result of the Company’s investment in an associate company (Sarh Capital Real Estate Company) of a real estate in the amount of 15,234,114 KWD without having an ownership document that proves that its associate company owns the mentioned real estate in spite of having registered it in its financial statements of several periods which is considered a violation of Article (68) previously mentioned.
Third: Provision of Item (3) of Article (126) of Law No. 7 of 2010 and its amendments:
It was proven to the Authority in a strict manner that he did not provide the Authority with a number of documents (bank statements) as follows:
a. All of its bank statements and the bank statements of a number of its subsidiaries and their subsidiaries in accordance with the Company’s letter dated 6/12/2020 on the pretext of the bank’s refusal to provide it with those statements because it hasn’t updated his data, and statement of the companies that it failed to provide the inspection team with its bank statements.
b. Full bank statements of a number of its subsidiaries and their subsidiaries without giving any reasons as follows:
• Arabian Pen Company.
• Al-Tatweer Capital Real Estate Company.
• Al-Sanabel Company.
• Economic Pen Company.
• Develop General Trading and Contracting Company.
c. Full bank statements for the period from 01/01/2018 to 15/11/2020.
Fourth: Provision of Item (3) of Article (127) of Law No. 7 of 2010 and its amendments:
The following was proven to the Authority in a strict manner:
a) The existence of salary transfers from subsidiaries to Al-Madina for Finance and Investment Company or from its associate companies, and when the Company was asked for the reasons behind the subsidiary and the associate company’s paying for the salaries of the employees of Al-Madina for Finance and Investment Company, it answered in a letter dated 30/11/2020 that “the reason behind not paying the salaries of the Company’s employees directly from the bank accounts of Al-Madina for Finance and Investment Company is having an executive attachment on the Company’s accounts by parties with which the Company has legal issues, and reserving the amounts allocated for the employees’ salaries by the bank and not transferring them to the Company’s employees might be expected.”
This is because Al-Madina for Finance and Investment Company has made financial transfers to Develop General Trading and Contracting Company (subsidiary) in accordance with written instructions to pay the salaries of the subsidiary’s employees, which indicates that the claims of Al-Madina for Finance and Investment Company regarding having an executive reservation on its accounts were incorrect and that it has paid the salaries of its subsidiary’s employees at the same time.
b) 44,000 KWD was transferred from AAN Digital Services Holding Company on 09/11/2020 to Real Capital Company. The Company reported to the inspection team that the purpose of this transaction is to transfer from an associate company, noting that pursuant to the structure submitted to the team by the Company as on 30/09/2020, AAN Digital Services Holding Company did not appear to be an associate company to Al-Madina for Finance and Investment Company.
Fifth: Provision of Items (6,8) of Article (5-1-1) of Module Seven (Clients’ Funds and Clients’ Assets) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not update some data of several clients of the portfolios managed by the Company.
Sixth: provision of Item (11) of Article (5-1-9) of Module Seven (Clients’ Funds and Clients’ Assets) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that the contracts of some of the Company’s clients did not include an item stipulating the importance of the Company and the client’s compliance with Law No. 7 of 2010 Regarding the Establishment of the Capital Markets Authority and Regulating Securities Activities and its Executive Bylaws and their amendments.
Seventh: Provision of Item (3) of Article (6-5) of Module Eight (Conduct of Business) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that the Company did not record telephone conversations or maintain electronic correspondences for one of the orders sent by the Company to the agent to execute one of the transactions.
Eighth: Provisions of Articles (9-1) and (9-3) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not take any procedure to protect the Company’s funds and its shareholders’ funds concerning its subsidiaries’ payment of salaries and the payments related to associate companies or other parties in accordance with verbal instructions which may cause legal risks for those companies in the future (in terms of not complying with the authorizations), in addition to representing financial risks (due to unavailability of written instructions).
Ninth: Provisions of Articles (3-40) and (4-6) of Module Sixteen (Anti-Money Laundering and Combating Financing or Terrorism) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
The following was proven to the Authority in a strict manner:
a. He did not obtain adequate information on the purpose of conducting several financial transfers and maintained records on the domestic and international transactions.
b. Conducting or receiving financial transfers without knowing the account number of the transferring or receiving account.
3) Mr. Mohamed Darweish AlShamali – Former Vice Chairman of the Board of Directors of Al-Madina for Finance and Investment Company – violated the following:
First: Provision of Item (3) of Article (66) of Law No. 7 of 2010 and its amendments, and Article (4-1-2) of Module Seven (Clients’ Funds and Clients Assets) of the Executive Bylaws of the mentioned Law:
It was proven to the Authority in a strict manner that he, in his capacity as Vice Chairman of Al-Madina for Finance and Investment Company, deposited the client’s funds in the Company’s accounts as a result of depositing the amounts transferred from Dubai related to Tabat Alkheir Company in its own bank account and not the bank account of the clients.
Second: Provision of Article (68) of Law No. 7 of 2010 and its amendments:
It was proven to the Authority in a strict manner unavailability of the ownership documents of the land located in Jeddah in the Kingdom of Saudi Arabia as a result of the Company’s investment in an associate company (Sarh Capital Real Estate Company) of a real estate in the amount of 15,234,114 KWD without having an ownership document that proves that its associate company owns the mentioned real estate in spite of having registered it in its financial statements of several periods which is considered a violation of Article (68) previously mentioned.
Third: Provision of Item (3) of Article (126) of Law No. 7 of 2010 and its amendments:
It was proven to the Authority in a strict manner that he did not provide the Authority with a number of documents (bank statements) as follows:
a. All of its bank statements and the bank statements of a number of its subsidiaries and their subsidiaries in accordance with the Company’s letter dated 6/12/2020 on the pretext of the bank’s refusal to provide it with those statements because it hasn’t updated his data, and statement of the companies that it failed to provide the inspection team with its bank statements.
b. Full bank statements of a number of its subsidiaries and their subsidiaries without giving any reasons as follows:
• Arabian Pen Company.
• Al-Tatweer Capital Real Estate Company.
• Al-Sanabel Company.
• Economic Pen Company.
• Develop General Trading and Contracting Company.
c. Full bank statements for the period from 01/01/2018 to 15/11/2020.
Fourth: Provision of Item (3) of Article (127) of Law No. 7 of 2010 and its amendments:
The following was proven to the Authority in a strict manner:
a) The existence of salary transfers from subsidiaries to Al-Madina for Finance and Investment Company or from its associate companies, and when the Company was asked for the reasons behind the subsidiary and the associate company’s paying for the salaries of the employees of Al-Madina for Finance and Investment Company, it answered in a letter dated 30/11/2020 that “the reason behind not paying the salaries of the Company’s employees directly from the bank accounts of Al-Madina for Finance and Investment Company is having an executive attachment on the Company’s accounts by parties with which the Company has legal issues, and reserving the amounts allocated for the employees’ salaries by the bank and not transferring them to the Company’s employees might be expected.”
This is because Al-Madina for Finance and Investment Company has made financial transfers to Develop General Trading and Contracting Company (subsidiary) in accordance with written instructions to pay the salaries of the subsidiary’s employees, which indicates that the claims of Al-Madina for Finance and Investment Company regarding having an executive reservation on its accounts were incorrect and that it has paid the salaries of its subsidiary’s employees at the same time.
b) 44,000 KWD was transferred from AAN Digital Services Holding Company on 09/11/2020 to Real Capital Company. The Company reported to the inspection team that the purpose of this transaction is to transfer from an associate company, noting that pursuant to the structure submitted to the team by the Company as on 30/09/2020, AAN Digital Services Holding Company did not appear to be an associate company to Al-Madina for Finance and Investment Company.
Fifth: Provision of Article (2-4) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he, in his capacity as a member of the Board of Directors of Al-Madina for Finance and Investment Company (at that time), did not take any procedures regarding the absence of one of the members of the Board of Directors, that is Dr. Abdel-Raouf Tawfiq, from the sessions, in addition to electing him as the Chairman of the Board even though the Board’s minutes of meetings undoubtedly indicate that he did not attend most of the Board’s meetings.
Sixth: Provisions of Article (3-1) and Item (5) of Article (3-10) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he, in his capacity as a member of the Board of Directors of Al-Madina for Finance and Investment Company (at that time), did not take any procedures regarding maintaining the interest of the Company’s shareholders and managing the Company’s resources optimally in regards with Khairan Real Estate Project that is registered in the financial statements of Al-Madina for Finance and Investment Company and owned by Mr. Ali AlShamali according to the documents submitted by it, even though the Board of Directors was content with a waiver letter signed by the mentioned gentlemen on an (A4) paper that was not dated and not authorized by the legal entities of the country in favor of one of its subsidiaries (Develop General Trading and Contracting Company) which may result in legal and financial risks and the loss of the Company’s shareholders’ rights in the future.
Seventh: Provisions of Articles (9-1) and (9-3) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he, in his capacity as a member of the Board of Directors of Al-Madina for Finance and Investment Company (at that time), did not take any procedures to protect the Company’s funds and its shareholders’ funds concerning its subsidiaries’ payment of salaries and the payments of associate companies or other parties in accordance with verbal instructions which may result in legal risks for those companies in the future (in terms of not complying with the authorizations) and financial risks (due to unavailability of written instructions).
Eighth: Provision of Article (11-4) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he, in his capacity as a member of the Board of Directors of Al-Madina for Finance and Investment Company (at that time), did not put in place mechanisms to evaluate the performance of each member of the Board of Directors.
Ninth: Provision of Article (3-40) of Module Sixteen of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
In addition, in his capacity as a member of the Board of Directors of Al-Madina for Finance and Investment Company (at that time), he did not comply with the provision of Article (4-6) of the mentioned Module:
The following was proven to the Authority in a strict manner:
a. He did not obtain adequate information on the purpose of conducting several financial transfers.
b. Conducting or receiving financial transfers without knowing the account number of the transferring or receiving account.
4) Mr. Ahmad Dawud Salman AlSabah – Member of the Board of Directors of Al-Madina for Finance and Investment Company – violated the following:
First: Provision of Article (2-4) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not take any procedures regarding the absence of one of the members of the Board of Directors, that is Dr. Abdel-Raouf Tawfiq, from the sessions, in addition to electing him as the Chairman of the Board even though the Board’s minutes of meetings undoubtedly indicate that he did not attend most of the Board’s meetings.
Second: Provisions of Articles (9-1) and (9-3) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not take any procedures to protect the Company’s funds and its shareholders’ funds concerning its subsidiaries’ payment of salaries and the payments related to associate companies or other parties in accordance with verbal instructions which may result in legal risks for those companies in the future (in terms of not complying with the authorizations) and financial risks (due to unavailability of written instructions).
Third: Provision of Article (11-4) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not put in place mechanisms to evaluate the performance of each member of the Board of Directors.
Fourth: Violating provision of Article (3-40) of Module Sixteen (Anti-Money Laundering and Combating Financing or Terrorism) of the Executive Bylaws of Law No. 7 of 2010 and their amendments and Article (4-6) of the mentioned Module that stipulated:
The following was proven to the Authority in a strict manner:
a. He did not obtain adequate information on the purpose of conducting several financial transfers.
b. Conducting or receiving financial transfers without knowing the account number of the transferring or receiving account.
5) Mr. Ahmad Abdul-Fattah Bayomi Bader – former Member of the Board of Directors of Al-Madina for Finance and Investment Company – violated the following:
First: Provision of Article (2-4) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not take any procedures regarding the absence of one of the members of the Board of Directors, that is Dr. Abdel-Raouf Tawfiq, from the sessions, in addition to electing him as the Chairman of the Board even though the Board’s minutes of meetings undoubtedly indicate that he did not attend most of the Board’s meetings.
Second: Provisions of Article (3-1) and Item (5) of Article (3-10) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not take any procedures regarding maintaining the interest of the Company’s shareholders and managing the Company’s resources optimally in regards with Khairan Real Estate Project that is registered in the financial statements of Al-Madina for Finance and Investment Company and owned by Mr. Ali AlShamali according to the documents submitted by it, even though the Board of Directors was content with a waiver letter signed by the mentioned gentlemen on an undated (A4) paper that was unauthorized by the legal entities of the country in favor of one of its subsidiaries (Develop General Trading and Contracting Company) which may result in legal and financial risks and the loss of the Company’s shareholders’ rights in the future.
Third: Provisions of Articles (9-1) and (9-3) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not take any procedures to protect the Company’s funds and its shareholders’ funds concerning its subsidiaries’ payment of salaries and the payments of associate companies or other parties in accordance with verbal instructions which may result in legal risks for those companies in the future (in terms of not complying with the authorizations) and financial risks (due to unavailability of written instructions).
Fourth: Provision of Article (11-4) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not put in place mechanisms to evaluate the performance of each member of the Board of Directors.
Fifth: Violating provision of Article (3-40) of Module Sixteen of the Executive Bylaws of Law No. 7 of 2010 and their amendments and Article (4-6) of the same Module:
The following was proven to the Authority in a strict manner:
a. He did not obtain adequate information on the purpose of conducting several financial transfers and maintain records on the domestic and international transactions.
b. Conducting or receiving financial transfers without knowing the account number of the transferring or receiving account.
6) Ms. Manal Abdul-Kareem Jassem Bin Bader – former Member of the Board of Directors of Al-Madina for Finance and Investment Company– violated the following:
First: Provision of Article (2-4) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that she did not take any procedures regarding the absence of one of the members of the Board of Directors, that is Dr. Abdel-Raouf Tawfiq, from the sessions, in addition to electing him as the Chairman of the Board even though the Board’s minutes of meetings undoubtedly indicate that he did not attend most of the Board’s meetings.
Second: Provisions of Article (3-1) and Item (5) of Article (3-10) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that she did not take any procedures regarding maintaining the interest of the Company’s shareholders and managing the Company’s resources optimally in regards with Khairan Real Estate Project that is registered in the financial statements of Al-Madina for Finance and Investment Company and owned by Mr. Ali AlShamali according to the documents submitted by it, even though the Board of Directors was content with a waiver letter signed by the mentioned gentlemen on an undated (A4) paper that was unauthorized by the legal entities of the country in favor of one of its subsidiaries (Develop General Trading and Contracting Company) which may result in legal and financial risks and the loss of the Company’s shareholders’ rights in the future.
Third: Provisions of Articles (9-1) and (9-3) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that she did not take any procedures to protect the Company’s funds and its shareholders’ funds concerning its subsidiaries’ payment of salaries and the payments of associate companies or other parties in accordance with verbal instructions which may result in legal risks for those companies in the future (in terms of not complying with the authorizations) and financial risks (due to unavailability of written instructions).
Fourth: Provision of Article (11-4) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that she did not put in place mechanisms to evaluate the performance of each member of the Board of Directors.
Fifth: Violating provision of Article (3-40) of Module Sixteen of the Executive Bylaws of Law No. 7 of 2010 and their amendments and Article (4-6) of the same Module:
The following was proven to the Authority in a strict manner:
a. She did not obtain adequate information on the purpose of conducting several financial transfers and maintain records on the domestic and international transactions.
b. Conducting or receiving financial transfers without knowing the account number of the transferring or receiving account.
7) Mr. Emad Hussain Neama –Member of the Board of Directors of Al-Madina for Finance and Investment Company– violated the following:
First: Provision of Article (2-4) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not take any procedures regarding the absence of one of the members of the Board of Directors, that is Dr. Abdel-Raouf Tawfiq, from the sessions, in addition to electing him as the Chairman of the Board even though the Board’s minutes of meetings undoubtedly indicate that he did not attend most of the Board’s meetings.
Second: Provisions of Article (3-1) and Item (5) of Article (3-10) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not take any procedures regarding maintaining the interest of the Company’s shareholders and managing the Company’s resources optimally in regards with Khairan Real Estate Project that is registered in the financial statements of Al-Madina for Finance and Investment Company and owned by Mr. Ali AlShamali according to the documents submitted by it, even though the Board of Directors was content with a waiver letter signed by the mentioned gentlemen on an undated (A4) paper that was unauthorized by the legal entities of the country in favor of one of its subsidiaries (Develop General Trading and Contracting Company) which may result in legal and financial risks and the loss of the Company’s shareholders’ rights in the future.
Third: Provisions of Articles (9-1) and (9-3) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not take any procedures to protect the Company’s funds and its shareholders’ funds concerning its subsidiaries’ payment of salaries and the payments of associate companies or other parties in accordance with verbal instructions which may result in legal risks for those companies in the future (in terms of not complying with the authorizations) and financial risks (due to unavailability of written instructions).
Fourth: Provision of Article (11-4) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not put in place mechanisms to evaluate the performance of each member of the Board of Directors.
Fifth: Provision of Article (3-40) of Module Sixteen of the Executive Bylaws of Law No. 7 of 2010 and their amendments and Article (4-6) of the same Module:
The following was proven to the Authority in a strict manner:
a. He did not obtain adequate information on the purpose of conducting several financial transfers and maintain records on the domestic and international transactions.
b. Conducting or receiving financial transfers without knowing the account number of the transferring or receiving account.
8) Mr. Aref Abdullah Musheet Al-Ajmi –Member of the Board of Directors of Al-Madina for Finance and Investment Company– violated the following:
First: Provision of Article (2-4) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not take any procedures regarding the absence of one of the members of the Board of Directors, that is Dr. Abdel-Raouf Tawfiq, from the sessions, in addition to electing him as the Chairman of the Board even though the Board’s minutes of meetings undoubtedly indicate that he did not attend most of the Board’s meetings.
Second: Provisions of Article (3-1) and Item (5) of Article (3-10) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not take any procedures regarding maintaining the interest of the Company’s shareholders and managing the Company’s resources optimally in regards with Khairan Real Estate Project that is registered in the financial statements of Al-Madina for Finance and Investment Company and owned by Mr. Ali AlShamali according to the documents submitted by it, even though the Board of Directors was content with a waiver letter signed by the mentioned gentlemen on an undated (A4) paper that was unauthorized by the legal entities of the country in favor of one of its subsidiaries (Develop General Trading and Contracting Company) which may result in legal and financial risks and the loss of the Company’s shareholders’ rights in the future.
Third: Provisions of Articles (9-1) and (9-3) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not take any procedures to protect the Company’s funds and its shareholders’ funds concerning its subsidiaries’ payment of salaries and the payments of associate companies or other parties in accordance with verbal instructions which may result in legal risks for those companies in the future (in terms of not complying with the authorizations) and financial risks (due to unavailability of written instructions).
Fourth: Provision of Article (11-4) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not put in place mechanisms to evaluate the performance of each member of the Board of Directors.
Fifth: Violating provision of Article (3-40) of Module Sixteen of the Executive Bylaws of Law No. 7 of 2010 and their amendments and Article (4-6) of the same Module:
The following was proven to the Authority in a strict manner:
a. He did not obtain adequate information on the purpose of conducting several financial transfers and maintain records on the domestic and international transactions.
b. Conducting or receiving financial transfers without knowing the account number of the transferring or receiving account.
9) Mr. Mohammad Ali Reda – Portfolio Manager of Al-Madina for Finance and Investment Company– violated the following:
First: Provision of Items (6,8) of Article (5-1-1) of Module Seven (Clients’ Funds and Clients’ Assets) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not update some data of several clients of the portfolios managed by it.
Second: Provision of Item (3) of Article (6-5) of Module Eight (Conduct of Business) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that no telephone conversations were recorded or maintained electronic correspondences for one of the orders sent by the Company to the agent to execute one of the transactions.
10) Mr. Mustafa Mohammad Ajami Abdul-Baqi Khaleefa – Risk Manager of Al-Madina for Finance and Investment Company– violated the following:
First: Provisions of Articles (9-1) and (9-3) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not take any procedures to protect the Company’s funds and its shareholders’ funds concerning its subsidiaries’ payment of salaries and the payments related to associate companies or other parties in accordance with verbal instructions which may result in legal risks for those companies in the future (in terms of not complying with the authorizations) and financial risks (due to unavailability of written instructions).
Second: Provision of Article (11-4) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not put in place mechanisms to evaluate the performance of each member of the Board of Directors.
Third: Provision of Article (3-40) of Module Sixteen of the Executive Bylaws of Law No. 7 of 2010 and their amendments and Article (4-6) of the same Module:
The following was proven to the Authority in a strict manner:
a. He did not obtain adequate information on the purpose of conducting several financial transfers and maintain records on the domestic and international transactions.
b. Conducting or receiving financial transfers without knowing the account number of the transferring or receiving account.
11) Mr. Islam Mohammad Wasfi Abdul-Rahman – Compliance Officer of Al-Madina for Finance and Investment Company– violated the following:
First: Provision of Items (6,8) of Article (5-1-1) of Module Seven (Clients’ Funds and Clients’ Assets) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not update some data of several clients of the portfolios managed by it.
Second: Provision of Item (11) of Article (5-1-9) of Module Seven (Clients’ Funds and Clients’ Assets) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that the contracts of some of the Company’s clients did not include an item stipulating the importance of the Company and the client’s compliance with Law No. 7 of 2010 Regarding the Establishment of the Capital Markets Authority and Regulating Securities Activities and its Executive Bylaws and their amendments.
Third: Provision of Item (3) of Article (6-5) of Module Eight (Conduct of Business) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that no telephone conversations were recorded or maintained electronic correspondences for one of the orders sent by the Company to the agent to execute one of the transactions.
12) Mr. Mohammad Abdul-Kareem Khashab – Financial Manager of Al-Madina for Finance and Investment Company– violated the following:
First: Provision of Item (3) of Article (66) of Law No. 7 of 2010 and its amendments and Article (4-1-2) of Module Seven (Clients’ Funds and Clients’ Assets) of the Executive Bylaws of the mentioned Law:
It was proven to the Authority in a strict manner that he deposited the client’s funds in the Company’s accounts as a result of depositing the amounts transferred from Dubai related to Tabat Alkheir Company in its own bank account and not the bank account of the clients.
Second: Provision of Article (68) of Law No. 7 of 2010 and its amendments:
It was proven to the Authority in a strict manner unavailability of the ownership documents of the land located in Jeddah in the Kingdom of Saudi Arabia as a result of the Company’s investment in an associate company (Sarh Capital Real Estate Company) of a real estate in the amount of 15,234,114 KWD without having an ownership document that proves that its associate company owns the mentioned real estate in spite of having registered it in its financial statements of several periods which is considered a violation of Article (68) previously mentioned.
Third: Provision of Item (3) of Article (126) of Law No. 7 of 2010 and its amendments:
It was proven to the Authority in a strict manner that he did not provide the Authority with a number of documents (bank statements) as follows:
a. All of its bank statements and the bank statements of a number of its subsidiaries and their subsidiaries in accordance with the Company’s letter dated 6/12/2020 on the pretext of the bank’s refusal to provide it with those statements because it hasn’t updated his data, and statement of the companies that it failed to provide the inspection team with its bank statements.
b. Full bank statements of a number of its subsidiaries and their subsidiaries without giving any reasons as follows:
• Arabian Pen Company.
• Al-Tatweer Capital Real Estate Company.
• Al-Sanabel Company.
• Economic Pen Company.
• Develop General Trading and Contracting Company.
c. Full bank statements for the period from 01/01/2018 to 15/11/2020.
Fourth: Provision of Item (3) of Article (127) of Law No. 7 of 2010 and its amendments:
The following was proven to the Authority in a strict manner:
a) The existence of salary transfers from subsidiaries to Al-Madina for Finance and Investment Company or from its associate companies, and when the Company was asked for the reasons behind the subsidiary and the associate company’s paying for the salaries of the employees of Al-Madina for Finance and Investment Company, it answered in a letter dated 30/11/2020 that “the reason behind not paying the salaries of the Company’s employees directly from the bank accounts of Al-Madina for Finance and Investment Company is having an executive attachment on the Company’s accounts by parties with which the Company has legal issues, and reserving the amounts allocated for the employees’ salaries by the bank and not transferring them to the Company’s employees might be expected.”
This is because Al-Madina for Finance and Investment Company has made financial transfers to Develop General Trading and Contracting Company (subsidiary) in accordance with written instructions to pay the salaries of the subsidiary’s employees, which indicates that the claims of Al-Madina for Finance and Investment Company regarding having an executive reservation on its accounts was inappropriate and that it has paid the salaries of its subsidiary’s employees at the same time.
b) 44,000 KWD was transferred from AAN Digital Services Holding Company on 09/11/2020 to Real Capital Company. The Company reported to the inspection team that the purpose of the transaction is to transfer from an associate company, noting that pursuant to the structure submitted to the team by the Company as on 30/09/2020, AAN Digital Services Holding Company did not appear to be an associate company to Al-Madina for Finance and Investment Company.
Fifth: Provisions of Articles (9-1) and (9-3) of Module Fifteen (Corporate Governance) of the Executive Bylaws of Law No. 7 of 2010 and their amendments:
It was proven to the Authority in a strict manner that he did not take any procedures to protect the Company’s funds and its shareholders’ funds concerning its subsidiaries’ payment of salaries and the payments of associate companies or other parties in accordance with verbal instructions which may result in legal risks for those companies in the future (in terms of not complying with the authorizations) and financial risks (due to unavailability of written instructions).
Sixth: Provision of Article (3-40) of Module Sixteen of the Executive Bylaws of Law No. 7 of 2010 and their amendments and Article (4-6) of the same Module:
The following was proven to the Authority in a strict manner:
a. He did not obtain adequate information on the purpose of conducting several financial transfers and maintain records on the domestic and international transactions.
b. Conducting or receiving financial transfers without knowing the account number of the transferring or receiving account.
13) Mr. Yousef Mousa Abdullah Al-Abdulrazzaq – Former Chief Executive Officer of Al-Madina for Finance and Investment Company– violated provision of Article (68) of Law No. 7 of 2010 and its amendments:
It was proven to the Authority in a strict manner unavailability of the ownership documents of the land located in Jeddah in the Kingdom of Saudi Arabia as a result of the Company’s investment in an associate company (Sarh Capital Real Estate Company) of a real estate in the amount of 15,234,114 KWD without having an ownership document that proves that its associate company owns the mentioned real estate in spite of having registered it in its financial statements of several periods.
The decision included the infliction of the following penalty: -
“1- Al-Madina for Finance and Investment Company, Mr. Emad Al-Deen Fahmi Assaf in his capacity as the Chief Executive Officer of Al-Madina for Finance and Investment Company, Mr. Mohamed Darweish AlShamali in his capacity as the Former Vice Chairman of the Board of Directors of Al-Madina for Finance and Investment Company, and Mr. Mohammad Abdul-Kareem Khashab in his capacity as the Financial Manager of Al-Madina for Finance and Investment Company are fined an amount of two thousand dinars for the violation attributed to them in Item One, and fined five thousand dinars for the violation attributed to them in Item Three, and fined twenty thousand dinars for the violation attributed to them in Item Four.
2- Al-Madina for Finance and Investment Company, Mr. Emad Al-Deen Fahmi Assaf in his capacity as the Chief Executive Officer of Al-Madina for Finance and Investment Company, Mr. Mohamed Darweish AlShamali in his capacity as the Former Vice Chairman of the Board of Directors of Al-Madina for Finance and Investment Company, Mr. Mohammad Abdul-Kareem Khashab in his capacity as the Financial Manager of Al-Madina for Finance and Investment Company, and Mr. Yousef Mousa Abdullah Al-Abdulrazzaq in his capacity as the Former Chief Executive Officer of Al-Madina for Finance and Investment Company are fined an amount of two thousand dinars for the violation attributed to them in Item Two in regards with the first three and for the attributed violation to the last according to the referral decision.
3- Madina for Finance and Investment Company, Mr. Emad Al-Deen Fahmi Assaf in his capacity as the Chief Executive Officer of Al-Madina for Finance and Investment Company, Mr. Mohammad Ali Reda in his capacity as Portfolio Manager of Al-Madina for Finance and Investment Company and Mr. Islam Mohammad Wasfi Abdul-Rahman in his capacity as Compliance Officer of Al-Madina for Finance and Investment Company are fined an amount of four thousand dinars for the violation attributed to them in Item Five in regards with the first and second and in Item one in regards with the second and third according to the referral decision.
4- Al-Madina for Finance and Investment Company, Mr. Emad Al-Deen Fahmi Assaf in his capacity as the Chief Executive Officer of Al-Madina for Finance and Investment Company, and Mr. Islam Mohammad Wasfi Abdul-Rahman in his capacity as Compliance Officer of Al-Madina for Finance and Investment Company are fined an amount of four thousand dinars for the violation attributed to the first in Item Seven, to the second in Item Six, and to the third in Item Two.
5- Al-Madina for Finance and Investment Company, Mr. Emad Al-Deen Fahmi Assaf in his capacity as the Chief Executive Officer of Al-Madina for Finance and Investment Company, Mr. Mohammad Ali Reda in his capacity as Portfolio Manager of Al-Madina for Finance and Investment Company and Mr. Islam Mohammad Wasfi Abdul-Rahman in his capacity as Compliance Officer of Al-Madina for Finance and Investment Company are fined an amount of one thousand dinars for the violation attributed to the first in Item Eight, to the second in Item Seven, to the third in Item Two, and to the fourth in Item Three.
6- Al-Madina for Finance and Investment Company, Mr. Emad Al-Deen Fahmi Assaf in his capacity as the Chief Executive Officer of Al-Madina for Finance and Investment Company, Mr. Mohamed Darweish AlShamali in his capacity as the Former Vice Chairman of the Board of Directors of Al-Madina for Finance and Investment Company, Mr. Mohammad Abdul-Kareem Khashab in his capacity as the Financial Manager of Al-Madina for Finance and Investment Company, Mr. Aref Abdullah Musheet Al-Ajmi in his capacity as Member of the Board of Directors of Al-Madina for Finance and Investment Company, Mr. Emad Hussain Neama in his capacity as Member of the Board of Directors of Al-Madina for Finance and Investment Company, Ms. Manal Abdul-Kareem Jassem Bin Bader in her capacity as Former Member of the Board of Directors of Al-Madina for Finance and Investment Company, Mr. Ahmad Abdul-Fattah Bayomi Bader in his capacity as Former Member of the Board of Directors of Al-Madina for Finance and Investment Company, Mr. Ahmad Dawud Salman AlSabah in his capacity as Member of the Board of Directors of Al-Madina for Finance and Investment Company and Mr. Mustafa Mohammad Ajami Abdul-Baqi Khaleefa in his capacity as the Risk Manager of Al-Madina for Finance and Investment Company are fined an amount of twenty thousand dinars for the violation attributed to first in Item Nine, to the second in Item Eight, to the third in Item Seven, to the fourth in Item Five, to the fifth in Item Three, to the sixth in Item Three, to the seventh in Item Third, to the eighth in Item Three, to the ninth in Item Two, and to the tenth in Item One.
7- Al-Madina for Finance and Investment Company, Mr. Mohamed Darweish AlShamali in his capacity as the Former Vice Chairman of the Board of Directors of Al-Madina for Finance and Investment Company, Mr. Ahmad Abdul-Fattah Bayomi Bader in his capacity as Former Member of the Board of Directors of Al-Madina for Finance and Investment Company, Mr. Ahmad Dawud Salman AlSabah in his capacity as Member of the Board of Directors of Al-Madina for Finance and Investment Company, Mr. Mustafa Mohammad Ajami Abdul-Baqi Khaleefa in his capacity as the Risk Manager of Al-Madina for Finance and Investment Company, Mr. Emad Hussain Neama in his capacity as Member of the Board of Directors of Al-Madina for Finance and Investment Company, Ms. Manal Abdul-Kareem Jassem Bin Bader in her capacity as Former Member of the Board of Directors of Al-Madina for Finance and Investment Company and Mr. Aref Abdullah Musheet Al-Ajmi in his capacity as Member of the Board of Directors of Al-Madina for Finance and Investment Company are fined an amount of one thousand dinars for the violation attributed to the first in Item Ten, to the second in Item Eight, to the third in Item Four, to the fourth in Item Three, to the fifth in Item Two, to the sixth in Item Four, to the seventh in Item Four, and to the eighth in Item Four.
8- Al-Madina for Finance and Investment Company, Mr. Emad Al-Deen Fahmi Assaf in his capacity as the Chief Executive Officer of Al-Madina for Finance and Investment Company, Mr. Mohamed Darweish AlShamali in his capacity as the Former Vice Chairman of the Board of Directors of Al-Madina for Finance and Investment Company, Mr. Mohammad Abdul-Kareem Khashab in his capacity as the Financial Manager of Al-Madina for Finance and Investment Company, Mr. Aref Abdullah Musheet Al-Ajmi in his capacity as Member of the Board of Directors of Al-Madina for Finance and Investment Company, Mr. Emad Hussain Neama in his capacity as Member of the Board of Directors of Al-Madina for Finance and Investment Company, Ms. Manal Abdul-Kareem Jassem Bin Bader in her capacity as Former Member of the Board of Directors of Al-Madina for Finance and Investment Company, Mr. Ahmad Abdul-Fattah Bayomi Bader in his capacity as Former Member of the Board of Directors of Al-Madina for Finance and Investment Company, Mr. Ahmad Dawud Salman AlSabah in his capacity as Member of the Board of Directors of Al-Madina for Finance and Investment Company and Mr. Mustafa Mohammad Ajami Abdul-Baqi Khaleefa in his capacity as the Risk Manager of Al-Madina for Finance and Investment Company are fined an amount of twenty thousand dinars for the violation attributed to the first in Item Eleven, to the second and third in Item Nine, to the fourth in Item Six, to the fifth, sixth, seventh and eighth in Item Five, to the ninth in Item Four, and to the tenth in Item Three.
9- Mr. Ahmad Dawud Salman AlSabah in his capacity as Member of the Board of Directors of Al-Madina for Finance and Investment Company is fined an amount of one thousand dinars for the violation attributed to him in Item One.
10- Each of Mr. Mohamed Darweish AlShamali in his capacity as the Former Vice Chairman of the Board of Directors of Al-Madina for Finance and Investment Company, Mr. Ahmad Abdul-Fattah Bayomi Bader in his capacity as Former Member of the Board of Directors of Al-Madina for Finance and Investment Company, Ms. Manal Abdul-Kareem Jassem Bin Bader in her capacity as Former Member of the Board of Directors of Al-Madina for Finance and Investment Company, Mr. Emad Hussain Neama in his capacity as Member of the Board of Directors of Al-Madina for Finance and Investment Company and Mr. Aref Abdullah Musheet Al-Ajmi in his capacity as Member of the Board of Directors of Al-Madina for Finance and Investment Company is fined an amount of one thousand dinars for the violation attributed to the first in Item Five and to the rest in Item One.
11- Each of Mr. Mohamed Darweish AlShamali in his capacity as the Former Vice Chairman of the Board of Directors of Al-Madina for Finance and Investment Company, Mr. Ahmad Abdul-Fattah Bayomi Bader in his capacity as Former Member of the Board of Directors of Al-Madina for Finance and Investment Company, Ms. Manal Abdul-Kareem Jassem Bin Bader in her capacity as Former Member of the Board of Directors of Al-Madina for Finance and Investment Company, Mr. Emad Hussain Neama in his capacity as Member of the Board of Directors of Al-Madina for Finance and Investment Company and Mr. Aref Abdullah Musheet Al-Ajmi in his capacity as Member of the Board of Directors of Al-Madina for Finance and Investment Company is fined an amount of ten thousand dinars for the violation attributed to the first in Item Six and to the rest in Item Two.”
In this regard, the CMA emphasizes the implementation of CMA Law and its Executive Bylaws on all persons dealing in securities activities, and urges them to comply with these Laws in order to promote investors' confidence, create a sound investment environment, and implement the Law according to the principles of fairness, transparency, and integrity in line with the best international practice.