Sonali Bank (UK) Limited
FCA enforcement action, 2016
What failed
The firm had governance failures, failed to be open with the regulator, and lacked adequate financial crime controls.
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The controls that would have caught it
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In short, the firm needed
- Three Lines of Defence & Accountability
- Firm-Wide Financial Crime Risk Assessment
- Board & Management Information Reporting
- Staff Training & Awareness
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
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.