UK – FCA imposes fine of £102m

The UK’s Financial Conduct Authority has issued a Decision Notice against Standard Chartered Bank including a fine of £102,163,200.

The fine related to KYC failings in general, with a focus on failure to conduct customer due diligence even in situations where sanctions red flags were evident. The FCA noted a lack of financial crime risk, and concerns as to the quality of the advice being given.

A particular focus were the UAE branches of the bank, and also export financing in relation to the export of military goods.

France – banking regulator finds breaches but does not fine

The Sanctions Commission of the French Banking Regulator (the ACPR) has published its decision from disciplinary proceedings against Raguram International.

Between 2015 and 2017, Raguram had failed to conduct KYC on its customers and failed to incorporate the lists of Eu sanctioned persons into its systems and controls framework.

At the time Raguram had not recognised that its controls environment was defective, but it had subsequently implemented stricter policies and procedures and purchased a compliance solution.

As a result of these steps no fine was imposed.

 

France – bank fined €50m for sanctions compliance failings

The ACPR in France has today announced the imposition of a fine of €50m against Banque Postale.

This is the largest fine imposed in France to date.

The fine was imposed for sanctions compliance failings and in particular the ability of designated persons to transfer funds through Banque Postale, even when not a customer, by “money order”.

Banque Postale has indicated an intention to appeal the fine.

Netherlands – Dutch National Bank fines of €170,000 upheld on appeal

The District Court of Rotterdam has upheld fines of €170,000 imposed by the Dutch National Bank on a payment services provider for breaches of Dutch sanctions law and AML rules.

The appeal was largely based on arguments that the internal compliance function had adequately performed its function. The court was highly critical of this argument, noting the lack of due diligence and periodic training.

Netherlands – conviction for breach of Iran sanctions

The District Court in the Hague has convicted an individual for the making of  unauthorised financial transfers to/from Iran in the years 2013 and 2014 of around €92,000.

The person was convicted but no sentence imposed on mental health grounds, while noting that ordinarily a conviction would result in a lengthy custodial sentence.

Various sums seized as part of the investigation were returned to the defendant as the prosecution had not proven that these sums related to particular criminal activity.

Netherlands – fine of €100,000 imposed on payment services provider

In 2015 the Dutch National Bank had imposed a financial penalty of €125,000 on an unnamed payment services provider for failings in relation to sanctions and PEP screening as part of a review by the bank.

The payment services provider appealed the decision.

On appeal to the District Court of Rotterdam the penalty was upheld but the fine reduced to €100,000.

The National Bank had originally calculated the fine as €550,000 which was then reduced due to the financial condition and size of the defendant.

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