The Financial Conduct Authority (FCA) has fined Deutsche Bank £163m for failing to maintain an adequate anti-money laundering (AML) control framework during the period between 1 January 2012 and 31 December 2015. This is the largest financial penalty for AML controls failings ever imposed by the FCA, or its predecessor the Financial Services Authority (FSA).
Claire Cross, Of Counsel at Corker Binning, commented: “After a year which ended with wide spread discussion about a potential softening in the regulator’s approach, the FCA has begun the New Year with a bang. The Deutsche Bank fine amounts to more than seven times the total amount levied by the watchdog last year and provides a marked contrast to last year’s highest total fine of £8.2 million in respect of Aviva’s failure to protect client money.
The FCA has repeatedly said that the quality of firms AML systems and controls is high on their regulatory agenda. Firms should check that their risk assessments are up to date and monitored correctly. Those who hold responsibility for anti-money laundering systems and controls under the Senior Managers Regime may want to think about checking the efficacy of these and to reacquaint themselves with the risks to the firm.
This latest fine, the largest to date imposed by either the FCA or FSA in respect of AML failings, contradicts any complacency that Andrew Bailey’s leadership would usher in a “softly softly” approach in respect to enforcement. Ignore it at your risk….”