Apolitics · https://apolika.com
Evidence file
Zenith Financial Limited
What this system held and said about the company on 24 October 2026, as of the moment the file was made, and what it rested on. Made on 24 October 2026, 19:45 UTC.
- listings in force
- 3
- ownership verdicts
- 0
- sources with their version
- 33
- limits stated
- 2
Listings
- LiftedMalta Financial Services Authority (MFSA)
Debarment
- In this state since
- 12 Sept 2026
- Designated
- 5 Oct 2012
- Reason given
- On 5th October 2012, the Malta Financial Services Authority imposed an administrative penalty of €12,112 on MFSP Financial Management Ltd, under the provisions of Article 16A of the Investment Services Act. The Authority is also restricting MFSP Financial Ltd’s licence from selling complex products both on an advisory and non-advisory basis in terms of the provisions of Article 8(1)(a) of the Investment Services Act. This restriction will remain in force for a period of three years, after which MFSP Financial Management Ltd may request the Authority to consider removing this restriction. The Authority’s investigation, into MFSP Financial Management Ltd’s sales practices in relation to the selling of complex products to retail investors, determined that in a number of instances MFSP Financial Management Ltd failed to act in the best interest of investors, as required in terms of the applicable regulatory framework. The following is a summary of the Authority’s findings and conclusions: Suitability and appropriateness assessment: Following the client file review as well as information provided by MFSP, the Authority came to the conclusion that there were instances (in the provision of non-advisory service) wherein a proper appropriateness test was not performed. Therefore with respect to these non-advisory clients, the Authority concluded that the concerned clients did not possess the relevant knowledge and experience to understand the risks involved in relation to the product sold. In the provision of advisory services, the Authority concluded that in certain instances, advisory clients were provided with unsuitable advice. In these instances clients did not satisfy the following criteria: [1] clients did not possess the relevant knowledge and experience to understand to understand the risks involved in relation to the products sold; and [2] the investor’s risk attitude and investment objective were in conflict with those of the financial product sold. The above findings represent a major concern to the Authority, particularly when one considers that a number of transactions (as reviewed by the Authority), occurred after the Authority had issued a circular on the sale of complex financial instruments in February 2009. The circular stated that Licence Holders will be retained responsible for any mis-selling of complex financial instruments. Record keeping: MFSP Financial Management Ltd was required to maintain sufficient records to be able to demonstrate compliance with the regulations and with the conditions of its investment services licence at all times. In one instance MFSP Financial Management Ltd failed to obtain the required information at the time when the transaction took place. File review: In view of the findings set out above the Authority will require a file review to be carried out for those clients who had invested in ARM Assured Income Plan and/or ARM Capital Growth Bond, with all resulting costs to be borne by MFSP Financial Management Ltd. This notice is being published in terms of the powers vested in the Authority under the provisions of the Malta Financial Services Authority Act.
- Document
- The publisher's document (https://registers.esma.europa.eu/publication/details?core=esma_registers_sanctions&docId=sn1005)
- Stated by
- ESMA Sanctions Register
- First recorded here
- 12 Sept 2026
- Listing id
- 1005
- In forceMalta Financial Services Authority (MFSA)
Debarment
- In this state since
- 12 Sept 2026
- Designated
- 29 Nov 2012
- Reason given
- MFSP Financial Management Ltd. has submitted an appeal on 31st October 2012 before the Financial Services Tribunal against the following MFSA’s decisions: [1] to impose this administrative penalty; [2] to restrict MFSP Financial Management Ltd. licence from selling complex products both on an advisory and non-advisory basis and [3] to carry out a file review for those clients who had invested in ARM Assured Income Plan and/or ARM Capital Growth Bond.
- Document
- The publisher's document (https://registers.esma.europa.eu/publication/details?core=esma_registers_sanctions&docId=sn1006)
- Stated by
- ESMA Sanctions Register
- First recorded here
- 12 Sept 2026
- Listing id
- 1006
- In forceMalta Financial Services Authority (MFSA)
MiFID
- In this state since
- 12 Sept 2026
- Designated
- 5 Oct 2012
- Reason given
- On 5th October 2012, the Malta Financial Services Authority imposed an administrative penalty of €12,112 on MFSP Financial Management Ltd, under the provisions of Article 16A of the Investment Services Act. The Authority is also restricting MFSP Financial Ltd’s licence from selling complex products both on an advisory and non-advisory basis in terms of the provisions of Article 8(1)(a) of the Investment Services Act. This restriction will remain in force for a period of three years, after which MFSP Financial Management Ltd may request the Authority to consider removing this restriction. The Authority’s investigation, into MFSP Financial Management Ltd’s sales practices in relation to the selling of complex products to retail investors, determined that in a number of instances MFSP Financial Management Ltd failed to act in the best interest of investors, as required in terms of the applicable regulatory framework. The following is a summary of the Authority’s findings and conclusions: Suitability and appropriateness assessment: Following the client file review as well as information provided by MFSP, the Authority came to the conclusion that there were instances (in the provision of non-advisory service) wherein a proper appropriateness test was not performed. Therefore with respect to these non-advisory clients, the Authority concluded that the concerned clients did not possess the relevant knowledge and experience to understand the risks involved in relation to the product sold. In the provision of advisory services, the Authority concluded that in certain instances, advisory clients were provided with unsuitable advice. In these instances clients did not satisfy the following criteria: [1] clients did not possess the relevant knowledge and experience to understand to understand the risks involved in relation to the products sold; and [2] the investor’s risk attitude and investment objective were in conflict with those of the financial product sold. The above findings represent a major concern to the Authority, particularly when one considers that a number of transactions (as reviewed by the Authority), occurred after the Authority had issued a circular on the sale of complex financial instruments in February 2009. The circular stated that Licence Holders will be retained responsible for any mis-selling of complex financial instruments. Record keeping: MFSP Financial Management Ltd was required to maintain sufficient records to be able to demonstrate compliance with the regulations and with the conditions of its investment services licence at all times. In one instance MFSP Financial Management Ltd failed to obtain the required information at the time when the transaction took place. File review: In view of the findings set out above the Authority will require a file review to be carried out for those clients who had invested in ARM Assured Income Plan and/or ARM Capital Growth Bond, with all resulting costs to be borne by MFSP Financial Management Ltd. This notice is being published in terms of the powers vested in the Authority under the provisions of the Malta Financial Services Authority Act.
- Document
- The publisher's document (https://registers.esma.europa.eu/publication/details?core=esma_registers_sanctions&docId=sn1005)
- Stated by
- ESMA Sanctions Register
- First recorded here
- 12 Sept 2026
- Listing id
- 1005
- In forceMalta Financial Services Authority (MFSA)
MiFID
- In this state since
- 12 Sept 2026
- Designated
- 29 Nov 2012
- Reason given
- MFSP Financial Management Ltd. has submitted an appeal on 31st October 2012 before the Financial Services Tribunal against the following MFSA’s decisions: [1] to impose this administrative penalty; [2] to restrict MFSP Financial Management Ltd. licence from selling complex products both on an advisory and non-advisory basis and [3] to carry out a file review for those clients who had invested in ARM Assured Income Plan and/or ARM Capital Growth Bond.
- Document
- The publisher's document (https://registers.esma.europa.eu/publication/details?core=esma_registers_sanctions&docId=sn1006)
- Stated by
- ESMA Sanctions Register
- First recorded here
- 12 Sept 2026
- Listing id
- 1006
Ownership verdicts
No ownership verdict was on file for this company on 24 October 2026.
What was checked
As recorded by the assessment reading taken on 25 September 2026, 17:45 UTC, the newest on or before the date. Only “checked, not found” means a source was read in full and held nothing for the company.
Sanctions lists
Found · 1 source. The source holds records for this company.
- ESMA Sanctions Register, checked 18 Sept 2026
Checked, not found · 32 sources. The source was read in full and holds nothing for this company.
- Australia DFAT Consolidated List, checked 18 Sept 2026
- Brazil CEIS (national procurement exclusions), checked 18 Sept 2026
- Brazil MTE employer register (lista suja), checked 18 Sept 2026
- Brazil TCU (firms declared inidôneas), checked 18 Sept 2026
- Canada Consolidated Autonomous Sanctions List, checked 22 Sept 2026
- EBRD Ineligible Entities, checked 24 Sept 2026
- EU Consolidated Sanctions List, checked 22 Sept 2026, list dated 5 Aug 2026
- France AMF blacklist of unauthorised actors, checked 25 Sept 2026
- IDB Sanctioned Firms and Individuals, checked 25 Sept 2026
- Japan MOF Sanctions List, checked 25 Sept 2026
- Latvia FID frozen assets register, checked 25 Sept 2026
- Malaysia BNM financial consumer alert list, checked 18 Sept 2026
- Malaysia SC investor alert list, checked 18 Sept 2026
- Moldova procurement ban list, checked 21 Sept 2026
- New Zealand Russia Sanctions Register, checked 22 Sept 2026
- Norges Bank (fund exclusions and observation), checked 22 Sept 2026
- OFAC Consolidated (non-SDN), checked 22 Sept 2026, list dated 14 Sept 2026
- OFAC SDN, checked 22 Sept 2026, list dated 18 Sept 2026
- Poland MSWiA sanctions list, checked 25 Sept 2026
- SAM.gov Exclusions (US federal), checked 18 Sept 2026
- Slovenia KPK business restrictions, checked 24 Sept 2026
- Swiss FINMA warning list, checked 25 Sept 2026
- Switzerland SECO Sanctions List, checked 23 Sept 2026, list dated 4 Sept 2026
- Taiwan SHTC export entity list, checked 19 Sept 2026
- Türkiye MASAK asset freezes, checked 24 Sept 2026
- UK OFSI Consolidated List, checked 13 Sept 2026, list dated 3 Jun 2026
- UK Sanctions List (FCDO), checked 21 Sept 2026, list dated 21 Sept 2026
- UN Security Council Consolidated List, checked 22 Sept 2026, list dated 21 Sept 2026
- US CBP forced-labour orders (WRO & Findings), checked 22 Sept 2026
- US Consolidated Screening List, checked 18 Sept 2026
- US UFLPA Entity List, checked 22 Sept 2026
- World Bank Listing of Ineligible Firms and Individuals, checked 24 Sept 2026
Debarment and exclusion lists
Checked, not found · 16 sources. The source was read in full and holds nothing for this company.
- Brazil CEIS (national procurement exclusions), checked 18 Sept 2026
- Brazil MTE employer register (lista suja), checked 18 Sept 2026
- Brazil TCU (firms declared inidôneas), checked 18 Sept 2026
- EBRD Ineligible Entities, checked 24 Sept 2026
- France AMF blacklist of unauthorised actors, checked 25 Sept 2026
- IDB Sanctioned Firms and Individuals, checked 25 Sept 2026
- Malaysia BNM financial consumer alert list, checked 18 Sept 2026
- Malaysia SC investor alert list, checked 18 Sept 2026
- Moldova procurement ban list, checked 21 Sept 2026
- Norges Bank (fund exclusions and observation), checked 22 Sept 2026
- SAM.gov Exclusions (US federal), checked 18 Sept 2026
- Slovenia KPK business restrictions, checked 24 Sept 2026
- Swiss FINMA warning list, checked 25 Sept 2026
- US CBP forced-labour orders (WRO & Findings), checked 22 Sept 2026
- US UFLPA Entity List, checked 22 Sept 2026
- World Bank Listing of Ineligible Firms and Individuals, checked 24 Sept 2026
Where the company is registered or connected
MT: registered here
No company register for this jurisdiction has been connected to this system, and none has been examined. No register here states who owns this jurisdiction's companies, so an ownership chain reaching one stops.
What this file cannot say
- Whether each listing was in force is rebuilt from what was recorded here: when it was first read, when a source stopped or resumed carrying it, and when its published term ended. A listing in force at an authority before this system first read it is shown from that first read.
- No ownership verdict is kept for this company. Verdicts are kept for companies registered where shareholders are read here: Estonia, Latvia and Poland.
What sources said
Legal name
zenith financial
ESMA Sanctions Register, since 12 Sept 2026, last confirmed by the date on 23 Oct 2026.
zenith financial
ESMA Sanctions Register, since 25 Sept 2026, last confirmed by the date on 23 Oct 2026.
Jurisdiction
MT
ESMA Sanctions Register, since 12 Sept 2026, last confirmed by the date on 23 Oct 2026.
MT
ESMA Sanctions Register, since 25 Sept 2026, last confirmed by the date on 23 Oct 2026.
Versions of the sources
For each source behind this file, the newest read made on or before the date: the version of it that stood.
Australia DFAT Consolidated List
Read on 19 October 2026. No date from the publisher is read for this file, so its age is not known here. 3,650 records read.
Brazil CEIS (national procurement exclusions)
Read on 21 October 2026. No date from the publisher is read for this file, so its age is not known here. 23,804 records read.
Brazil MTE employer register (lista suja)
Read on 21 October 2026. No date from the publisher is read for this file, so its age is not known here. 508 records read.
Brazil TCU (firms declared inidôneas)
Read on 22 October 2026. No date from the publisher is read for this file, so its age is not known here. 94 records read.
Canada Consolidated Autonomous Sanctions List
Read on 19 October 2026. No date from the publisher is read for this file, so its age is not known here. 5,708 records read.
EBRD Ineligible Entities
Read on 22 October 2026. No date from the publisher is read for this file, so its age is not known here. 1,278 records read.
ESMA Sanctions Register
Read on 23 October 2026. No date from the publisher is read for this file, so its age is not known here. 845 records read.
EU Consolidated Sanctions List
Read on 19 October 2026. The publisher dates the file 15 October 2026, 4 days before it was read. 6,234 records read. Publisher's version: globalFileId 185699.
France AMF blacklist of unauthorised actors
Read on 23 October 2026. No date from the publisher is read for this file, so its age is not known here. 2,574 records read.
IDB Sanctioned Firms and Individuals
Read on 23 October 2026. No date from the publisher is read for this file, so its age is not known here. 530 records read.
Japan MOF Sanctions List
Read on 19 October 2026. No date from the publisher is read for this file, so its age is not known here. 2,900 records read.
Latvia FID frozen assets register
Read on 20 October 2026. No date from the publisher is read for this file, so its age is not known here. 183 records read.
Malaysia BNM financial consumer alert list
Read on 19 October 2026. No date from the publisher is read for this file, so its age is not known here. 588 records read.
Malaysia SC investor alert list
Read on 19 October 2026. No date from the publisher is read for this file, so its age is not known here. 1,795 records read.
Moldova procurement ban list
Read on 29 September 2026. No date from the publisher is read for this file, so its age is not known here. 22 records read.
New Zealand Russia Sanctions Register
Read on 20 October 2026. No date from the publisher is read for this file, so its age is not known here. 529 records read.
Norges Bank (fund exclusions and observation)
Read on 20 October 2026. No date from the publisher is read for this file, so its age is not known here. 201 records read.
OFAC Consolidated (non-SDN)
Read on 19 October 2026. The publisher dates the file 14 September 2026, 35 days before it was read. 481 records read.
OFAC SDN
Read on 19 October 2026. The publisher dates the file 15 October 2026, 4 days before it was read. 17,556 records read.
Poland MSWiA sanctions list
Read on 21 October 2026. No date from the publisher is read for this file, so its age is not known here. 131 records read.
SAM.gov Exclusions (US federal)
Read on 24 October 2026. No date from the publisher is read for this file, so its age is not known here. 10,194 records read.
Slovenia KPK business restrictions
Read on 15 October 2026. No date from the publisher is read for this file, so its age is not known here. 4,351 records read.
Swiss FINMA warning list
Read on 19 October 2026. No date from the publisher is read for this file, so its age is not known here. 2,372 records read.
Switzerland SECO Sanctions List
Read on 19 October 2026. The publisher dates the file 15 October 2026, 4 days before it was read. 7,040 records read.
Taiwan SHTC export entity list
Read on 21 October 2026. No date from the publisher is read for this file, so its age is not known here. 11,664 records read.
Türkiye MASAK asset freezes
Read on 22 October 2026. No date from the publisher is read for this file, so its age is not known here. 2,304 records read.
UK OFSI Consolidated List
Read on 8 October 2026. The file carries no date of its own; its newest record is dated 3 June 2026, 127 days before it was read. Newest designation in the file: 2025-12-19. 5,120 records read.
UK Sanctions List (FCDO)
Read on 19 October 2026. The publisher dates the file 16 October 2026, 3 days before it was read. 5,705 records read.
UN Security Council Consolidated List
Read on 19 October 2026. The publisher dates the file 17 October 2026, 2 days before it was read. 1,010 records read.
US CBP forced-labour orders (WRO & Findings)
Read on 20 October 2026. No date from the publisher is read for this file, so its age is not known here. 63 records read.
US Consolidated Screening List
Read on 19 October 2026. No date from the publisher is read for this file, so its age is not known here. 6,474 records read.
US UFLPA Entity List
Read on 20 October 2026. No date from the publisher is read for this file, so its age is not known here. 205 records read.
World Bank Listing of Ineligible Firms and Individuals
Read on 23 October 2026. No date from the publisher is read for this file, so its age is not known here. 1,539 records read.
The assessment reading
- Taken
- 25 September 2026, 17:45 UTC
- Methodology
- Version 5
- Level
- Low
- Score recorded
- 45 of 100
- Digest
e6320bb156980c338ee1b32d35ac3e0e1acfe021A fingerprint of everything the reading says. The same reading always has this digest, and any change in it gives another.- Reading id
6f861b18-e281-4e78-906d-92c7dbbf4623
This file
- Address
- https://apolika.com/entities/ed2ddc03-c1be-4846-806c-8dcaeec33bf5/evidence?as_of=2026-10-24The same address gives the same day's file tomorrow. What was recorded after the date is not in it.
- Made
- 24 October 2026, 19:45 UTC