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03 Jan 2019

FCA fines for AML failings: important guidance for CEOs and boards


On 4 December 2018 the FCA published a Decision Notice in respect of Mohammed Ataur Rahman Prodhan, imposing a fine of £76,400 on the former CEO of Sonali Bank (UK) Ltd ("SBUK") for failings in relation to AML systems and controls.

The obligations of CEOs and other senior managers as regards regulatory compliance (and the extent to which senior managers can be held liable for regulatory or compliance failings) was explored in the leading case of John Pottage v The Financial Services Authority (in which this firm acted for John Pottage).

Drawing on the observations of the Upper Tribunal in the Pottage case, the recent Decision Notice in respect of Mr Prodhan (which is subject to reference to the Upper Tribunal), and also the FCA's new Financial Crime Guide (issued December 2018) a number of important, practical lessons on AML Compliance can be discerned, and, in particular, the "reasonable steps" which senior managers should take – as a matter of routine – to meet ever-growing FCA expectations around AML and financial crime.

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Alan Ward

Alan Ward

T:  +44 20 7809 2295 M:  Email Alan | Vcard Office:  London

Tony Woodcock

Tony Woodcock

T:  +44 20 7809 2349 M:  +44 7825 625 903 Email Tony | Vcard Office:  London