The Financial Services Authority has fined Coutts £8.75 million for breaches of principle 3 (management and control) between December 2007 and November 2010. Coutts agreed to settle at an early stage of the FSA's investigation without which the fine would have been £12.5 million.
The FSA found that Coutts had breached principle 3 as it failed to take reasonable care to establish and maintain effective anti-money laundering (AML) systems and controls in relation to customers that posed a higher money laundering risk. The FSA found that the failings at Coutts were serious, systemic and persisted for almost three years during which time Coutts was expanding its customer base and staff were incentivised to increase the number of international customers taken on. The FSA's expectation was for appropriate systems and controls to be in place particularly with regard to the prevention of the risk of money laundering and the potential for handling the proceeds of crime. The FSA found that Coutts
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