The Financial Conduct Authority (FCA) has kicked off its 2023 focus on anti-money laundering (AML) with fines against two banks for AML compliance failures. This follows enforcement action against six further regulated firms or individuals in the past 12 months for failures related to AML systems and controls.
A unifying theme across the FCA’s recent decisions is the identification of AML compliance failures in the absence of direct evidence that money laundering has occurred. Principle 3 of the FCA’s Principles for Business requires a regulated firm to “take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems”.
