The Financial Conduct Authority recently announced on June 23, 2022 that it fined Ghana International Bank Plc (GIB) £5.8 million after finding that the bank failed to perform certain anti-money laundering and counter-terrorist financing checks on its correspondent banking activities in violation of Regulations 14(1), 14(3) and 20(1) of the Money Laundering Regulations 2007.
The FCA reports that the GIB, a banking company based in the UK, provided services to overseas banks enabling them to provide products and services that they would otherwise not be able to provide, including making payments in different currencies and across borders. In an effort to reduce the higher risk of money laundering and terrorist financing associated with these correspondent banking services, the FCA requires banks to perform extra checks on the correspondent banking customers. However, the FCA discovered that between 2012 and 2016, GIB not only failed to adequately perform additional checks when the relationships with overseas banks were established, but GIB was also unable to demonstrate that it had assessed the banks’ AML controls, failed to perform annual reviews on the information provided by the banks, and failed to establish appropriate policies and procedures for its staff or adequately train its staff to properly scrutinize transactions. In December 2016, as a result of these findings, GIB voluntarily agreed that it would not take on new customers – a restriction that remains in place. The GIB also continues to work with the FCA and an independent expert in order to improve its financial crime controls.
Despite the significant deficiencies found in GIB’s AML program, the FCA found no evidence that actual money laundering activities had occurred. The FCA also reports that it reduced GIB’s fine by 30 percent because the bank did not dispute the FCA’s findings and agreed to settle the matter as soon as possible.