Ian Ryan

Ian Ryan

Partner - Business Crime and Regulatory

The FCA published two very interesting final notices today, one in respect of Sonali Bank (UK) Ltd and one in respect of that bank’s erstwhile MLRO, Mr Steven Smith.

The notices illustrate the vulnerability of an MLRO in this type of situation. Mr Smith inherited a situation where the bank was failing in its compliance functions, and despite being overworked, under resourced and under supported by the Bank’s senior management and board, he was still held personally accountable for his failure to perform his MLRO function properly, and fined £17,900 and prohibited from holding similar positions in the future.

This underlines, if it needed underlining, that the MLRO remains in the firing line and if things go wrong he or she will carry the can.

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