Highest FCA Fines of 2023

Posted by

Matt Green

on 23 May 2023


The FCA has had a relatively quiet year on the fines front thus far. We analyse the nature of these breaches and the fine amounts.

FCA fines 2023

The grand total of notable FCA fines issued in 2023 comes to just over £20m. With only three significant penalties dished out so far, each penalty holds significant weight.

Failure to have adequate anti-money laundering (AML) systems and controls in place has brought the risk of financial crime into the spotlight.

Top FCA fines in 2023

  1. Banque Havilland S.A - £10m
  2. Guaranty Trust Bank (UK) Limited (GT Bank) - £7.6m
  3. Al Rayan Bank PLC - £4m

We continuously track the largest Financial Conduct Authority (FCA) fines, including those from 2019, 2020, 2021 and most recently, 2022.

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The biggest FCA fines in detail

1. Banque Havilland S.A (fined £10m)

The FCA has fined private bank Banque Havilland an amount of £10m after it found the bank was behind a document outlining steps to harm the Qatari economy. The steps included ways to create a misleading impression of the Qatari market by using manipulative trading practices.

It is believed that Banque Havilland's aim was to devalue the Qatari Riyal, and the FCA has stated that the bank engaged in the commission of a financial crime. 

Furthermore, the FCA imposed separate fines on three former employees at the bank's London branch who were involved in creating and distributing the document. Former CEO Edmund Rowland, David Weller, and Vladimir Bolelyy are also banned from working in the financial service sector in the UK again.

2. Guaranty Trust Bank (UK) Limited (GT Bank) (fined £7.6m)

Breaches of PRIN 3

Guaranty Trust Bank (UK) Ltd (GT Bank) has been issued a fine of £7.6m by the FCA following lapses in its AML systems and controls. The FCA found that the GT Bank failed to conduct sufficient customer risk assessments, and they often neglected to assess or document the money laundering risks to customers.

Furthermore, GT Bank failed to meet the regulation standard of monitoring customer transactions and business relationships. Following these both external and internal sources highlighting these regulatory lapses, the bank failed to take appropriate action.

Since GT Bank did not dispute the FCA's findings, they have qualified for a 30% discount in their penalty.

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3. Al Rayan Bank PLC (fined £4m)

Breaches of Principle 3

The FCA has issued a £4m fine to London-based bank Al Rayan Bank for failures in its AML rules. Over the period from April 2015 to November 2017, Al Bank did not carry out appropriate checks on money passing through the bank.

This failure means that the firm didn't check the source of its customers' funds when it was required to ensure that the money was not linked to a financial crime. Despite the FCA raising its concerns over the matter, the bank failed to take appropriate action.

"The FCA will continue to raise the stakes for firms that do not take their financial crime responsibilities seriously, especially in preventing money laundering risks which harms confidence and integrity in our market and in preventing financial crime”.

- Mark Steward, Market Oversight, FCA

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