Canara Bank
FCA enforcement action, 2018
What failed
The firm breached Principle 3 and SYSC by failing to maintain adequate financial crime systems and controls.
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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
- Firm-Wide Financial Crime Risk Assessment
- Independent Assurance & Control Testing
Customer Identification & Verification (CIP/CDD)
PreventiveCustomer Due Diligence
Before a customer can use the account, prove they are who they say they are using reliable, independent evidence, not just what they typed into the form.
- Starting threshold:
- 100% of mandatory identity attributes matched to >=1 independent source before activation; for individuals require 2 of 3 attributes from electronic verification OR 1 authenticated photo-ID document plus a passing liveness check; document image quality / face-match confidence >= 90%.
- First-line owner:
- Onboarding / KYC Operations team
Structuring & Smurfing Detection
DetectiveTransaction Monitoring
Catches people breaking one big payment into lots of smaller ones to stay under reporting or alerting limits, including when several accounts act together.
- Starting threshold:
- 3 or more transactions each within 10% below a relevant threshold (e.g. the firm's cash reporting or alerting limit) by one customer in a rolling 7 days, OR 4+ sub-threshold credits from distinct linked parties funnelling to one beneficiary within a rolling 14 days.
- First-line owner:
- Financial Crime Operations Analyst (transaction monitoring 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.