On November 25, 2015, the Financial Conduct Authority fined Barclays Bank plc £72,069,400 for failing to minimize financial crime risks appropriately. The failings of the bank relate to a transaction worth around £1.88 billion that was arranged and executed for ultra-high net worth clients that were politically exposed and should therefore have been subject to enhanced due diligence checks. The FCA found that a lower level of due diligence was undertaken by Barclays for those clients and that Barclays had not followed its own standard procedures, going to unacceptable lengths to accommodate the clients in question. Whilst the FCA did not specifically find that the transaction itself involved financial crime, this is the largest fine to be imposed by the FCA (and its predecessor, the Financial Services Authority) for failing to minimize financial crime risks.

The FCA notice is available at: http://www.fca.org.uk/static/documents/final-notices/barclays-bank-nov-2015.pdf.