Al Rayan Bank PLC
FCA enforcement action, 2023
What failed
The firm breached PRIN 3 by failing to maintain adequate financial crime controls in its retail banking operations.
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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
PreventiveCustomer 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
Typologies behind this case
Related enforcement cases
Next steps
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.