These failings are particularly serious as they affected customers based in countries associated with a higher risk of money laundering, bribery or corruption, including accounts held by politically exposed person.
GT Bank, a subsidiary of Nigerian Guaranty Trust Bank PLC, opened an office in London in May 2008 offering retail and wholesale banking products and services to private, corporate and institutional clients.
The FCA’s predecessor, the Financial Services Authority, reviewed GT Bank’s controls as part of a thematic review into banks’ management of money-laundering risks in 2010. The review of GT Bank raised significant concerns and after further investigation, the FCA found that GT Bank failed to establish effective AML policies and procedures when they established their UK operations.
As a result, GT Bank was not able to fully understand or assess their higher risk customers' activities. This breached FCA Principle 3, which requires firms to take reasonable care to organise and control their affairs responsibly and effectively, and a number of our rules on systems and controls.
Tracey McDermott, director of enforcement and financial crime, said:
"Banks are at the front line in ensuring the proceeds of crime do not enter the UK financial system. GT Bank’s failures were serious and systemic and resulted in an unacceptable risk of handling the proceeds of crime.
"Regardless of whether firms are well established or new to the industry they must ensure that they have systems and controls to manage money laundering risk.
"The FCA will continue to focus on potential money laundering risks, in line with our objectives to protect and enhance the integrity of the UK financial system and will be 'intensive and intrusive' taking action where serious issues are identified."
GT Bank settled at an early stage of the investigation and qualified for a 30% discount on its fine. Without the discount the fine would have been £750,000.
