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Al Rayan Bank PLC

FCA enforcement action, 2023

£4m
financial penalty
Money LaunderingAMLPRINCIPLES
Where this fine sits
Rank (largest first)
#22 of 44
Top percentile
Top 50%
vs. median fine
1.1x
smallestlargest

What failed

The firm breached PRIN 3 by failing to maintain adequate financial crime controls in its retail banking operations.

Read the final notice

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The controls that would have caught it

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In short, the firm needed

  • Customer Risk Assessment & Rating
  • Transaction-Monitoring Scenario Coverage Assurance
  • Ongoing CDD & Periodic Review
  • Firm-Wide Financial Crime Risk Assessment

Beneficial Ownership Identification & Verification

Preventive

Customer Due Diligence

For any company or trust customer, find out who really owns or controls it (the actual humans), and prove it, before letting them transact.

Starting threshold:
>25% direct or indirect ownership/voting rights defines a beneficial owner; verify identity of every such person; require the full chain to be resolved to natural persons within 3 ownership layers before activation, or document why a deeper/opaque chain is acceptable.
First-line owner:
KYC Operations / Corporate Onboarding team
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Typologies behind this case

Related enforcement cases

Enforcement data is sourced from the FCA fines dataset. The control mapping is an analyst view of what would have addressed the failings described in the public notice, not a statement of the regulator's findings.