On August 2, the U.K. Financial Services Authority (FSA) announced that it had fined Turkish Bank (UK) Ltd (TBUK) £294,000 (approximately $456,000) for breaches of the Money Laundering Regulations 2007 (MLR). The FSA found that the breaches—which related to TBUK’s correspondent banking arrangements—were widespread and lasted over two and a half years. The FSA stated that the anti-money laundering (AML) breaches had led to “an unacceptable risk that TBUK could have been used to launder money.”

TBUK’s breaches of the MLR included failing to:

• establish and maintain appropriate and risk-sensitive AML policies and procedures for its correspondent banking relationships;
   
• carry out adequate due diligence on, and ongoing monitoring of, the respondent banks it dealt with and failing to reconsider these relationships when this was not possible; and
   
• maintain adequate records relating to the above.

While the FSA concluded that the failings were not deliberate or reckless, they were considered to be “more serious” because the FSA had previously warned TBUK of deficiencies in its approach to AML controls over correspondent banking.

TBUK agreed to settle with the FSA at an early stage of the investigation. As a result of the early settlement and the firm’s co-operation, the fine of £420,000 (approximately $650,000) was reduced by 30%.

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