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£107m [x7] key failings @ Santander UK Plc [Dec 2022]


The Financial Conduct Authority fined [Dec 2022] Santander UK Plc £107m.

The fine was for serious gaps in the bank's anti-money laundering controls.

Here are x7 key failings:

  1. Governance arrangements were insufficient to identify, assess, monitor, and manage ML/TF risks.
  2. The implementation of AML/CFT Policies and procedures was flawed.
  3. Operational silos compromised risk assessments and effectively distorted the Three Lines of Defence system.
  4. Onboarding deficiencies led to inaccurate risk assessments when identifying the customers' nature of business.
  5. The SAR Unit had no formal feedback process for actioning closure recommendations.
  6. Key individuals responsible for investigating internal reports did not understand the approach taken in the investigation and received no training
  7. Off boarding delays resulted in suspicious high-risk accounts remaining open.



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