In a Final Notice issued on 4 March 2015, the Bank of Beirut was fined £2.1 million (Stage 1: 30% discount: breach of principle 11) and was restricted from acquiring new customers who are resident or incorporated in high risk jurisdictions for the next 126 days. Following supervisory visits in 2010 and 2011, the FCA identified serious deficiencies in the firm’s implementation of anti-money laundering and financial crime procedures to customers’ files. It set out various remedial actions to address these risks and issues. However, the Bank of Beirut provided misleading information to the FCA indicating it had completed the remedial actions when it had not. The FCA issued Final Notices to Anthony Wills (former compliance officer at Bank of Beirut), who was fined £19,600 (Stage 1: 30% discount), and Michael Allin (internal auditor at Bank of Beirut), who was fined £9,900 (Stage 1: 30% discount), for failure to deal with the regulator in an open and cooperative way and failure to disclose appropriately to the regulator information of which it would reasonably expect notice. The sanctions imposed on the Bank of Beirut and these two approved persons affirm the deterrent nature of the FCA’s action.