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Money Laundering Bulletin

What a difference a decade doesn’t make

Ten years ago the UK Financial Services Authority (FSA) published a woeful report on UK banks’ management of high money laundering risk situations. [1] MLB duly covered the catalogue of elementary failings with a headline ‘Incredible indifference to “credible deterrence”’ (then the watchword of FSA director of enforcement Margaret Cole). [2] After that sorry exposé one might reasonably expect matters to have improved. But no, a ‘Dear CEO letter’ addressed to retail banks by the Financial Conduct Authority (FCA), successor to FSA, dated 21 May 2021 [3], suggests little has changed: again, the ‘common control failings’ identified are fundamental in nature.

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