Standard Bank PLC
FCA enforcement action, 2014
What failed
The firm lacked adequate AML policies for corporate customers connected to politically exposed persons.
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
- PEP Identification & Enhanced Due Diligence
- PEP Screening
- Enhanced Due Diligence Programme
- Beneficial Ownership Identification & Verification
Source of Wealth Corroboration (High Risk / PEP)
PreventiveCustomer Due Diligence
For high-risk and PEP customers, understand and prove how they built their overall wealth (not just one deposit), and make sure that story is plausible and independently corroborated.
- Starting threshold:
- Mandatory documented and corroborated source of wealth for all high-risk and PEP relationships before onboarding; flag for escalation where corroborated wealth covers less than 75% of estimated net worth, or where wealth exceeds 10x the customer's known/declared legitimate income or official remuneration with no documented explanation.
- First-line owner:
- Relationship Management (private banking / wealth) with KYC support
PEP Identification & Enhanced Due Diligence
PreventiveCustomer Due Diligence
Spot customers (and their close family and associates) who hold or held prominent public office, then apply extra checks and senior approval because they carry higher corruption risk.
- Starting threshold:
- PEP screening match score >= 85% auto-routes to manual adjudication; all confirmed PEPs require senior management approval before activation; family members and close associates screened to the same standard; ex-PEP de-classification only after a documented risk assessment and a minimum 12-month stand-down (longer for foreign/high-corruption-risk roles).
- First-line owner:
- Screening Operations / KYC 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.