National Westminster Bank Plc
FCA enforcement action, 2021
What failed
Automated and manual red flags were not acted on as a commercial customer deposited around £365m, much of it in cash, far beyond its expected activity.
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
- Cash-deposit anomaly rules tuned to expected turnover
- Activity-versus-expected-profile monitoring with hard stops
- EDD and re-rating triggers for cash-intensive businesses
- Escalation when alerts repeat without resolution
Cash Deposit Anomaly Monitoring
DetectiveTransaction Monitoring
Flags when a customer pays in cash that does not fit their declared business or income, so unexplained cash can be reviewed before it disappears into the system.
- Starting threshold:
- Cumulative cash deposits > 3x declared expected monthly cash turnover in a rolling 30 days, OR cash > 80% of total credits where the declared profile is not cash-intensive.
- First-line owner:
- Financial Crime Operations Analyst (transaction monitoring 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)
Transaction-Monitoring Scenario Coverage Assurance
DetectiveTransaction Monitoring
Checks that the firm's monitoring rules actually cover the risks the firm faces, so no major money-laundering pattern is left with no rule watching for it.
- Starting threshold:
- Zero unmapped assessed risks and zero in-scope product/channel populations missing from TM data feeds; any single coverage gap is an exception requiring a remediation plan with an owner and date.
- First-line owner:
- TM / Detection Engineering Lead (scenario estate owner)
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.