Guaranty Trust Bank (UK) Ltd (GTB) has been fined £525,000 (discounted by 30% for settlement at an early stage of the investigation) by the FCA for failures in its anti-money laundering controls. The Final Notice, which can be found here, stated that, between 19 May 2008 and 19 July 2010, GTB had breached FCA Principle 3 by failing to have in place effective anti-money laundering systems and controls for high risk customers. The bank was a subsidiary of Nigerian Guaranty Trust Bank PLC, and acted as a gateway to the UK financial system for customers from countries with less stringent anti-money laundering rules than the UK.
Particular failures identified included the 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.
GTB has now taken steps to remedy its failures, improving anti-money laundering systems and controls, and strengthening its compliance department.