The Luxembourg financial services regulator, the CSSF, has announced today the imposition of a fine of €1.56 million on Banque Degroof Petercam Luxembourg SA.
The fine followed an inspection which started in September 2019, and relates to compliance failings in the context of AML and terrorist financing, and a failure to adequately screen clients for inclusion on EU sanctions lists.
The CSSF noted that remedial steps have been taken by the bank since the inspection of 2019/2020.
It was reported today that the Swiss authorities are currently investigating 30 possible breaches of frozen asset reporting under the Swiss sanctions against Russia.
It was also stated that one of these cases had already been referred to federal prosecutors.
The Luxembourg financial services regulator, the CSSF, has today imposed a a fine of €145,000 on Unzer Luxembourg SA for AML and sanctions compliance failings.
The penalty notice noted that the failings, including in sanctions screening, were identified as part of an on-site inspection in 2020 and 2021, and noted that the lack of a fine took into consideration the bank’s efforts at remediation.
The Luxembourg financial services regulator, the CSSF, has today imposed a reprimand on Banque J Safra Sarasin (Luxembourg) SA for AML and sanctions compliance failings.
The penalty notice noted that the failings, including in sanctions screening, were identified as part of an on-site inspection in 2019, and noted that the lack of a fine took into consideration the bank’s efforts at remediation.
The Luxembourg financial services regulator, the CSSF, has today fined BEMO Europe Banque Privée SA €356,000 for AML and sanctions compliance failings.
The penalty notice noted that the failings, including in sanctions screening, were identified as part of an on-site inspection in 2020, and noted that the size of the fine took into consideration the bank’s efforts at remediation.
The UK’s Financial Conduct Authority has fined Ghana International Bank Plc for sanctions compliance failures, including a lack of periodic screening, only screening after onboarding had been completed, and an insufficiently detailed or practical sanctions policy.
The bank was fined £5,829,900 after a 30% reduction for cooperation and early settlement.
The Danish Financial Services Authority has today published its findings in relation to Danske Bank’s internal compliance function.
The findings included:
The Danish FSA finds that there is a risk that possible breaches of sanctions may not be detected by the bank’s sanctions screening because the bank does not have procedures in place for cooperation, including the exchange of information, between the units responsible for sanctions screening, customer due diligence data and transaction monitoring.
The Danish FSA also finds that there is a risk that possible breaches of sanctions may not be detected and escalated to the bank’s team of experts in the Sanctions & Embargo Team, who investigate possible breaches of sanctions, because the employees of the units of the bank who deal with customer due diligence data and transaction monitoring to prevent breaches of sanctions receive no training.
In addition, the Danish FSA finds that there is an increased risk of employee errors and abuse in the sanctions area because of matters relating to the bank’s internal controls in the sanctions area, including the fact that the four-eyes principle is not applied in connection with the screening of customers, the organisation of controls of manual processes for escalation as well as the organisational embedding of the Sanctions and Embargo Team in Group Compliance.
OFSI has today issued a second penalty for breach of the EU’s Russian sanctions, again using its civil enforcement powers.
The penalty notice is available here.
The penalty, of £36,393.45, was imposed on Clear Junction Limited. The transactions in this case are the same as those relating to TransferGo, although OFSI makes clear that it was Clear Junction which reported the transactions. It is noteworthy that some of the impugned transactions took place after the first report to OFSI.
OFSI’s notice also makes the point that the breach here was of the EU’s Russian sanctions, and that post-Brexit OFSI will continue to investigate breaches of the EU’s regulations that may have taken place before Brexit.
Today OFSI announced it had imposed a £50,000 financial penalty on TransferGo in the latest example of the use of its civil enforcement powers.
OFSI’s penalty notice is available here.
The fine was imposed in relation to 16 transactions over nearly 2 years valued at just £7,674.77 through which funds were made available Russian National Commercial Bank, which is a designated person under the EU’s Russian sanctions.
TransferGo did not self report but did cooperate with the investigation.
OFSI’s notice makes clear that the RNCB was not the intended beneficiary of the transactions, rather the recipients of the transfers were accounts held by non-designated persons with RNCB. OFSI has made clear that as funds held in bank accounts are legally held by the banks, that these transfers all amounted to making funds available to RNCB
