On March 26, the UK Financial Services Authority (FSA) announced that it had fined Coutts & Company £8.75 million (approximately $14 million) in relation to failures to take reasonable care to establish and maintain effective anti-money laundering (AML) systems and controls relating to high risk customers including politically exposed persons (PEPs). The fine was imposed for breaches of Principle 3 of the FSA’s Principles for Businesses (“a firm must take reasonable care to organize and control its affairs responsibly and effectively, with adequate risk management systems”) and FSA rules relating to Senior Management Arrangements, Systems and Controls (SYSC 6.1.1R and SYSC 6.3.1R).

The FSA described Coutts’ failings as serious and systemic and as having resulted in the creation of an unacceptable risk of Coutts handling the proceeds of crime.