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 – appeal against Liberian sanctions conviction dismissed

The Dutch Supreme Court has dismissed the appeal against the 19-year sentence for (amongst other crimes) breach of the EU’s Liberian sanctions.

The appeal was largely on the grounds that the Liberian government had granted an amnesty which was said to apply. The Supreme Court disagreed, and in any event held that such an amnesty is incompatible with Dutch obligations under the European Convention of Human Rights.

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