Latvia – bank fined €1.1m for Russian sanctions compliance failings

The Latvian financial services regulator (the FKTK) has fined SEB Bank €1.8 million, of which €1,121,140 related to shortcomings in the bank’s sanctions compliance.

The inspections leading to the fine had taken place in 2017 and 2018.

The failings are said to have been specific to the EU’s Russian sanctions in regulation 269/2014 (as amended).

The fine was stated to be for not screening for companies and other assets owned by designated persons.

France – Council of State upholds €50m fine for bank’s sanctions compliance failings

The French Council of State has today dismissed the appeal by Banque Postale against the fine of €50m imposed by the regulator, the ACPR.

The fine was imposed for EU sanctions compliance failings which had permitted designated persons subject to asset freezes to still transfer funds through the use of “money orders”.

This is the largest fine imposed by the French authorities.

See our earlier post in relation to the original fine.

Luxembourg – regulator imposes fines for sanctions screening failures

The Luxembourg financial services regulator, the CSSF, has today fined Banque Puilaetco Dewaay Luxembourg SA €15,000 for AML and sanctions compliance failings.

The penalty notice noted that the failing was “a temporary deficiency of the ongoing screening system of the client database against sanction lists”, and noted that the deficiency had since been remediated.

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.

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The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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