FCA fines Commerzbank London £37,805,400 over anti-money laundering failures

The Final Notice contains some points to note for professional services firms generally. There were no suggestions of money laundering taking place. Breaches included a significant backlog of refreshing CDD checks due to understaffing, leading to an exceptions process which was inadequately understood. A file review of CDD by Compliance failed to identify failures over the risks associated with clients that had an “element of state ownership (in high risk jurisdictions), and a number of politically-exposed individuals on their board”. There were multiple failures in relation to PEPs and sanctions screening, and in identifying beneficial ownership, in many cases being too willing to accept responses and information from the customer without independently verifying or challenging them. See here.

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