Guaranty Trust Bank (UK) Ltd has been fined £525,000 (including a 30% discount for early stage settlement) by the FCA for failings in its anti-money laundering controls. The investigation arose following the FSA's 2010 thematic review of the management of higher risk money laundering situations at various banks. Following its investigation into the position at Guaranty Trust Bank, the FCA concluded that between 19 May 2008 and 19 July 2010, the bank had breached FCA Principle 3 by failing to implement effective anti-money laundering systems and controls for high risk customers. Particular failings identified by the FCA included a failure to assess or document potential money laundering risks, to screen customers against sanction lists or check if they were Politically Exposed Persons (PEPs), to check the purpose and nature of new customers’ accounts or the source of their funds, and to review activity on high risk customers’ accounts. The FCA considered the failings to be particularly serious because they related to customers based in countries associated with a higher risk of money laundering, bribery or corruption.