International Bank of Ghana to Pay Over £5m for Failing to Meet Money Laundering Obligations – White Collar Crime, Anti-Corruption and Fraud

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Niall Hearty of financial crime specialists Rahman Ravelli looks into the case.

The Ghana International Bank (GIB) must now pay over £5m for money laundering failings.

The Financial Conduct Authority (FCA) has fined the bank £5,829,900 for weak anti-money laundering and counter-terrorist financing controls linked to its correspondent banking business.

GIB provided correspondent banking services to foreign banks. This has allowed these banks to provide products and services that they could not otherwise offer, including making payments in different currencies and across borders.

Banks are required by the FCA to carry out additional checks on their correspondent banking customers to reduce the higher risk of money laundering and terrorist financing associated with the service.

In announcing the fine, the FCA said that between January 1, 2012 and December 31, 2016, GIB failed to adequately perform the additional checks required when establishing relationships with foreign banks. GIB had not demonstrated that it had assessed the anti-money laundering controls of these banks. GIB also failed to undertake annual reviews of the information it held on the banks with which it had relationships, failed to provide staff with adequate training on how to properly review transactions, and failed to has not established appropriate policies and procedures for staff.

In December 2016, the FCA visited GIB to review its financial crime controls. Due to concerns identified by the FCA, GIB has voluntarily agreed not to accept new clients. This restriction remains in place.

Although no evidence of money laundering was found, the FCA said “the risk of money laundering resulting from these deficient systems was significant”.

GIB did not contest the FCA’s findings and agreed to pay a financial settlement as soon as possible, meaning it was granted a 30% discount on the financial penalty of £8,328,500.

The sanction imposed on GIB reflects the seriousness of the breaches according to the FCA. GIB’s failure to carry out the required checks meant that the bank was unable to properly review transactions worth £9.5bn processed during the aforementioned period.

The fine is another reminder of the obligations imposed on regulated companies in the prevention of financial crime.

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