The FCA has fined Guaranty Trust Bank (UK) Ltd (GT Bank) £525,000 (including a 30 per cent discount for early settlement) for failings in its anti-money laundering (AML) controls for high risk customers between May 2008 and June 2010 in breach of Principle 3 of the FCA’s Principles for Businesses and the Senior Management Arrangements, Systems and Controls rules 6.1.1R and 6.3.1R of the FCA Handbook.

GT Bank, a subsidiary of Nigerian Guaranty Trust Bank PLC, opened an office in London in May 2008 and provided financial services to a significant number of higher risk customers, most of whom came from jurisdictions that do not have AML requirements equivalent to those in the UK.
The FCA’s predecessor, the FSA, reviewed the bank’s controls as part of a thematic review into banks’ management of money laundering risks in 2010 and found that GT Bank failed to establish effective AML policies and procedures when they established their UK operations. GT Bank failed to:

• assess or document potential money-laundering risks posed by higher risk customers;
• screen prospective customers against sanctions lists or databases of politically exposed persons (PEPs);
• obtain and/or document senior management approval to establish a business relationship with PEPs;
• establish the purpose and intended nature of prospective customers’ accounts or the sources of higher risk customers’ wealth or funds; and
• review the activity of higher risk customers’ accounts and check that the information they held on these customers was up to date.

A copy of GT Bank’s final notice = http://www.fca.org.uk/your-fca/documents/final-notices/2013/guaranty-trust-bank-uk-limited
and related FCA press release  =  http://www.fca.org.uk/news/fca-fines-guaranty-trust-bank-uk-ltd