Ghana International Bank Plc
FCA enforcement action, 2022
What failed
The firm breached the Money Laundering Regulations in its corporate banking by failing to meet required AML standards.
Read the final noticeThe controls that would have caught it
These controls map directly to this failure. Open any one in the Control Builder to set your own thresholds, owners and systems, then export an implementation-ready spec.
In short, the firm needed
- Customer Identification & Verification (CIP/CDD)
- Customer Risk Assessment & Rating
- Ongoing CDD & Periodic Review
- Transaction-Monitoring Scenario Coverage Assurance
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
Source of Funds Verification
PreventiveCustomer Due Diligence
For a specific large or unusual deposit, establish and evidence where that exact money came from before it is used.
- Starting threshold:
- Verify source of funds for any single inflow >= GBP 10,000 (or local equivalent) or aggregated inflows >= GBP 10,000 in 30 days; lower to GBP 0 (verify all) for high-risk and PEP relationships; always verify where the payer differs from the customer or the funds originate in a high-risk third country (reg.33).
- First-line owner:
- Relationship Management / Onboarding with KYC Operations
Correspondent Banking Due Diligence
PreventiveScreening
Before banking another bank, the firm checks that respondent's ownership, controls and customers so it does not unknowingly process crime or sanctions risk on their behalf.
- Starting threshold:
- No relationship without completed EDD and senior sign-off; respondent or owner screening hit at fuzzy score >= 85% holds onboarding for review; payable-through / nested access prohibited unless specifically assessed and controlled. Shell banks are an automatic decline.
- First-line owner:
- Correspondent Banking / Financial Institutions relationship 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.