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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