On 23 June, Crowell Moring in the US published an article following this year’s penalties for AML and sanctions failings, the latest being the £37 million penalty for Commerzbank AG. It looks at the failures identified by the FCA in the bank’s financial crime controls. It notes that the penalty is the second-largest to be imposed by the FCA following the penalty it imposed on Standard Chartered Bank last year of £102 million over breaches of AML regulations. The article notes that the FCA provides useful reminders for financial institutions about what they are required to do in order to manage their AML risks. It also says that it will also be important for financial institutions to ensure that, if they are given warnings by the regulator about weaknesses in their AML control frameworks, they take immediate remedial action. Based on recent enforcement actions, the firm says, regulators in the UK are beginning to police and enforce financial crime regulations more stringently and successfully.




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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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