The penalties relate to 2 separate clients where gaps in onboarding and ongoing controls led to the provision of financial services to the facilitation of money-laundering, fraud, and other criminal offences.
Key failings by the bank include:
➡️ Not confirming the customer was permitted to hold customer funds by checking the Financial Services Register during onboarding. As a result Barclays will voluntarily pay £6.3m to the clients of the customer who have a shortfall in their reclaimed funds.
➡️ Poor data collection leading to inadequate ongoing monitoring of the customer while they received over £48m from a large-scale money-laundering operation.
➡️ Failing to act on information received from law enforcement on suspected money-laundering and only launching a review when enforcement action was made against NatWest for a similar relationship.
✅ The message from the regulator is clear: reacting only once penalties are being imposed out is too little, too late.
✅ Firms must make sure their KYC and ongoing monitoring controls are robust, so that bad actors can be identified and decisive action can be taken before whether that’s enhanced controls or customer exits.
💡 Plenitude is appointed to the FCA’s Skilled Person Panel for Financial Crime, enabling us to conduct independent Section 166 reviews of regulated firms’ financial crime controls and support others throughout the process. Visit our website for more information or get in touch directly: https://www.plenitudeconsulting.com/services/s166-skilled-person