REGINA (THE FINANCIAL CONDUCT AUTHORITY) -v- NATIONAL WESTMINSTER
BANK PLC Southwark Crown Court Sentencing Remarks of Mrs Justice Cockerill 13 December 2021
1. The Defendant, National Westminster Bank Plc (NatWest or the Bank), appears for sentence for three offences contrary to the Money Laundering Regulations 2007 (“the Regulations”) to which it has pleaded guilty, pursuant to a Plea Agreement dated 6 October 2021.
2.Those offences are:
- Between 7 November 2013 and 23 June 2016, failing to comply with the requirement to conduct ongoing monitoring of a business relationship contrary to regulations 8(1) and 45(1) of the Money Laundering Regulations 2007;
- Between 8 November 2012 and 23 June 2016, failing to comply with the requirement to determine the extent of ongoing monitoring on a risk-sensitive basis and be able to demonstrate to its supervisory authority that the extent of the ongoing monitoring is appropriate in view of the risks of money laundering and terrorist financing contrary to regulations 8(3) and 45(1) of the Money Laundering Regulations 2007;
- Between 8 November 2012 and 23 June 2016 failing to apply enhanced ongoing monitoring to its business relationship with Fowler Oldfield, in a situation which by its nature presented a higher risk of:
Money laundering and terrorist financing contrary to regulations 14(1) and 45(1) of the Money Laundering Regulations 2007.
- This is the first criminal conviction of a bank under the Regulations.
- The Bank’s pleas were offered on an agreed factual basis set out in a lengthy Statement of Facts attached to the Plea Agreement. I reach the sentence in this case on the basis of that Statement of Facts, which is attached to these sentencing remarks as an Appendix.
Meet the team of industry experts behind ComsureFind out more
Keep up to date with the very latest news from ComsureFind out more
View our latest imagery from our news and workFind out more
Think we can help you and your business? Chat to us todayGet In Touch
As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email email@example.com.