Coutts, HMQ's bank and bankers to at least 1/2 the Bar of England and Wales has been fined £8.75M (reduced by third for an early settlement) because it failed to take reasonable care to establish and maintain effective anti-money laundering (AML) systems and controls in relation to customers that posed a higher money laundering risk than standard customers (high risk customers).
Woops...... the FSA added:
Coutts’ failings merit the imposition of a significant financial penalty. The FSA considers the failings to be particularly serious because:
Coutts is a high profile bank with a leading position in the private banking market and is a gateway to the UK financial system for high net worth international customers. It was particularly important, therefore, that Coutts had robust systems and controls to prevent and detect money laundering;
the markets and customers that the Firm was targeting included certain jurisdictions with AML requirements which were not equivalent to those in the UK and which carried an inherently high risk in respect of money laundering;
the Firm provided financial services to a large number of high risk customers, the number of which approximately doubled during the Relevant Period, and it handled considerable sums of money on behalf of those customers;
the failings persisted for a period of almost three years;
the failings were not identified by the Firm;
the Firm, along with three other institutions within The Royal Bank of Scotland Group, was fined in August 2010 for failing to put in place adequate financial crime systems and controls, in that case in relation to UK financial sanctions; and
the failings in this Notice also occurred in a period during which the FSA successfully brought and published other Enforcement cases against a number of institutions for shortcomings in their financial crime systems and controls. As such, the Firm ought to have been aware of the importance of systems and controls to prevent and detect all types of financial crime, including money laundering.