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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.

  1. This is the first criminal conviction of a bank under the Regulations.
  2. 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.


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