According to the FCA announcement, GT Bank failed to undertake adequate customer risk assessments, often not assessing or documenting the money laundering risks posed by its customers. The bank also failed to monitor customer transactions and business relationships to the required standard. These weaknesses were repeatedly highlighted to GT Bank by internal and external sources, including the FCA, but GT Bank failed to take appropriate action.
From early 2018 GT Bank stopped taking on new customers. Later that year, the bank agreed to broader voluntary restrictions on business, given the FCA’s ongoing concerns. Requirements remained in place until the middle of 2021 when they were lifted after the bank completed a remediation plan checked by an independent third party.
GT Bank’s conduct is particularly egregious as this is not the first time the bank has faced enforcement action in relation to its AML controls, with the FCA fining GT Bank £525,000 in August 2013 for severe and systemic failings.
GT Bank has not disputed the FCA’s findings and agreed to settle, which means it has qualified for a 30% discount. Without this discount, the financial penalty would have been £10,959,700.
