Compliance Fines & Settlements

The consequences of regulatory compliance breaches can be severe. They range from losing professional accreditation to multi-million-pound fines or lengthy prison sentences.

Even companies with well-trained staff and thorough compliance processes may get caught off guard. And sometimes breaches aren't accidental!

We track penalties across key areas of compliance, from AML, bribery and competition law to GDPR.

We hope others can avoid the same mistakes by understanding what went wrong.

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Compliance Fines

How to avoid compliance fines

Complying with regulations is a requirement for all companies. Unsurprisingly, this is the only way to avoid compliance fines. However, judging by the number of fines issued annually, this is easier said than done. As you will soon see, the consequences for breaching regulations in any area of compliance can be dire.

This overview checks in with the key areas of compliance to investigate the penalties associated with specific regulatory breaches. We guide you on how to avoid being on the receiving end of one of these fines. In line with this, we offer free resources to help with your regulatory compliance journey.

AML Fines

It is a requirement for companies in the UK that operate in sectors covered by Money Laundering Regulations to register with a supervisory authority. This could be the FCA (for regulated financial services firms), HMRC or their professional body. These authorities provide regulations and guidance on how to prevent money laundering.

Any company found in breach of money laundering regulations will face penalties that can range from fines to prison sentences in more severe cases. The supervisory authority will determine the magnitude of the penalty. Some considerations made by HMRC, for example, include:

  • the seriousness of the offence
  • the reason for non-compliance
  • the compliance history of the business
  • the relative size of the business
  • the amount exposed to money laundering

Recent AML Fines

A summary of what happened in 2020 and 2021:

Simple steps to avoid AML fines

  • Conduct initial and ongoing client due diligence using a risk-based approach with no exceptions.
  • Look out for anything unusual or suspicious about any customer or transaction - pay particular attention to high-risk customers and jurisdictions.
  • Report any knowledge or suspicion of money laundering to the relevant authorities immediately, and take no further action until authorised to do so.
  • Avoid tipping off anyone who has been reported for money laundering or terrorist financing.

Free AML Training Resources

MLRO Responsibilities Checklist

Are you wondering what a Money Laundering Reporting Officer (MLRO) does and what their key responsibilities should be? Our checklist identifies the 20 key areas of responsibility that should fall under the MLRO's remit.

Free MLRO Responsibilities Checklist

Fourth Money Laundering Directive Training (4AMLD/4MLD/AMLD4)

Our free training presentation provides an ideal platform to help your employees understand what 4MLD means and the responsibilities they have as employees to ensure your business is up-to-date on this Directive.

Free 4MLD Training Presentation

Fifth Money Laundering Directive Training (5AMLD/5MLD/AMLD5)

Our free training presentation provides an ideal platform to help your employees understand what 5MLD means and the responsibilities they have as employees to ensure your business is up-to-date on this Directive.

Free 5MLD Training Presentation

Sixth Money Laundering Directive Training (6AMLD/6MLD/AMLD6)

Our free training presentation provides an ideal platform to help your employees understand what 6MLD means and the responsibilities they have as employees to ensure your business is up-to-date on this Directive.

6AMLD Training Presentation

Bribery & Corruption Fines

The Bribery Act creates a "strict liability" offence for companies in the UK that fail to prevent bribery by their staff, agents, subsidiaries and other 'associated persons'. If an associated person offers or pays a bribe on a company's behalf, that company can face unlimited fines even if they didn't sanction the bribe or know about the bribe payment. The only defence available to a company in this position is having "adequate procedures" to prevent bribery.

 Due to the nature of bribery's financial gains, disgorgement is often the most significant penalty firms face. This dwarfs the actual fine by an enormous amount. 

Apart from the financial damage incurred, companies could also suffer:

  • reputational damage
  • loss in revenue
  • the disqualification of a firm's directors for up to 15 years

Individuals who are found guilty of a bribery offence face penalties in the form of:

  • imprisonment for up to 10 years
  • a fine which could be unlimited

Recent Bribery & Corruption Fines

Here's a summary of the largest bribery fines in 2020 and 2021:

Simple steps to avoid bribery fines

  • Never offer money or anything of value in return for improper performance of any function.
  • Ensure that gifts, hospitality, donations, sponsorship and expenses are proportionate and in line with industry-standard policies and thresholds.
  • Never make facilitation payments to speed up processes or 'jump the queue'.
  • Ensure you report any suspicion or knowledge of bribery to the relevant authorities immediately.

Free Bribery Training Resources

Anti-bribery Online Training Module

Discover the gold standard in digital anti-bribery training. Our free online training module is produced in partnership with Transparency International UK and provides comprehensive anti-corruption training for front-line staff.

Free Anti-Bribery E-learning Module

Anti-bribery Training Presentation

Teach your team about UK anti-bribery laws and red flags with our free, interactive training presentation. This is a time-efficient way of educating your staff on behaviour that could be considered corrupt.

Free Anti-Bribery Training Presentation

Corporate Gifts & Hospitality Checklist

Are you wondering where bribery starts and goodwill ends? Our free checklist will help your employees stay compliant when giving or receiving gifts or hospitality.

Free Corporate Gifts Checklist

Anti-bribery Good Practice Guide

Our best practice guide is simple yet comprehensive and helps to ensure that your bribery training is compliant. Discover how RegTech tools and e-learning can assist you in implementing the best practices and avoiding common pitfalls.

Anti-bribery Training Tips

Competition Fines

Having a healthy level of competition in business keeps things interesting, and it is often favourable to consumers. However, there are limitations on what businesses can and can't do. Competition law ensures that businesses are competing on a level playing field.

The UK and EU competition law prohibit two main types of ant-competitive activity: abuse of dominant position and anti-competitive agreements. Some of the most common unlawful actions that fall under these areas include:

  • agreements to share markets or sources of supply
  • pay-for-delay agreements
  • bilateral agreements
  • price-fixing
  • market abuse
  • splitting markets
  • cartel behaviour between competitors

The consequences for breaking competition law can be severe. Businesses can face hefty penalties, and individuals could be banned from management or have to do jail time.

Recent Competition Fines

Here's a summary of the largest competition fines in 2020 and 2021:

Simple steps to avoid competition fines

Competition law is a complex area covering many different types of anti-competitive behaviour. So here are just a few basic tips to stay compliant.

  • Never discuss or enter into agreements with competitors - regarding prices, margins, market shares or production volumes.
  • Never discuss future pricing plans and promotions with suppliers - or discuss RRPs with retailers.
  • Don't impose price, territorial or online sales restrictions on suppliers or distributors - unless you are certain that it is legally permissible to do so in that instance.
  • Don't act in a way that restricts competition in markets where you enjoy a dominant position - by, for instance, refusing to supply, prohibiting discounting, imposing sole obligations or entering "pay-for-delay" deals.
  • Don't discuss anything commercially sensitive with competitors - including prices, markets, territories, strategies or - as it is illegal.

Free Competition Training Resources

Competition Law Training Presentation

Our free, interactive training presentation provides an overview of the key points of competition law in an easily digestible format.

Competition Law Training Presentation

FCA Fines

The Financial Conduct Authority (FCA) aims to protect consumers, promote fair competition and enhance market integrity. However, getting on the wrong side of the FCA can cost a UK company dearly. Financial penalties for market abuse and breaching FCA regulations and competition law can amount to millions. Apart from issuing fines, the FCA's enforcement powers include:

  • prohibiting individuals from carrying on regulated activities
  • withdrawing a firm's authorisation
  • suspending firms and individuals from undertaking regulated activities
  • publicly announcing the start of disciplinary action
  • involving criminal prosecutions to tackle financial crime
  • issuing warnings and alerts about unauthorised firms

Recent FCA Fines

Here's a summary of the largest FCA fines over the past four years:

Simple steps to avoid FCA fines

The FCA's 'Principles for Business' (PRIN) outline the fundamental obligations for firms under the regulatory regime.

According to the FCA principle 3, a firm "must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems". This statement refers to a firm's:

  • Robust governance arrangements - rules, practice and processes.
  • Skills, knowledge and expertise of staff - in other words, train people!
  • Outsourcing responsibilities - know your suppliers and make sure they are compliant.
  • Record-keeping - keep records, and make sure they are accurate and up-to-date.
  • Conflicts of interest - again, keep a compliance register to avoid issues.

Free FCA Training Resources

FCA Prescribed Responsibilities Desk Aid

The FCA has a list of 'Prescribed Responsibilities' (PRs) that each firm needs to allocate to Senior Managers. Our free desk aid provides a reference guide to PRs, which will help those unfamiliar with the system or allow quick checks when there's a change in personnel.

Free Prescribed Responsibilities Desk Aid

Fit & Proper Training Presentation

Fit and proper processes need to be rigorous and aim for positive endorsements of an individual's fitness and propriety and the absence of negative indicators. Our fitness and training presentation will help to explain this further.

Free F&P Training Presentation

Fit & Proper Assessment Tips

The FCA handbook provides firms with guidance, but firms need to decide when and how they conduct assessments. This is why knowing the common pitfalls and recognising the difference between positive and negative indicators is so important. Our free desk aid will help cover both areas and provide assessment tips.

Free F&P Assessments Desk Aid

Non-financial Misconduct Training Aid

The FCA has indicated that its view on non-financial misconduct is shifting to ensure that individuals operate to the highest standard of personal ethics. Our scenario-based training will help you understand how to react to non-financial misconduct.

Free Non-financial Misconduct Training

FCA Conduct Rules Training Aid

Employees subject to Conduct Rules need the training to understand the rules and apply them in their specific roles. Our free desk aid offers ten tips to ensure your staff completely understand and adhere to conduct rules.

Free Conduct Rules Training Aid

Free Vulnerable Customers Desk Aid

Customer vulnerability is a topic that has received much attention in recent times. Our free desk aid provides seven checks to fully ensure that your staff understand and adhere to FCA guidelines.

Free Vulnerable Customers Checklist

MiFID II Training Presentation

The FCA implemented its second Markets in Financial Instruments Directive (MiFID II) in January 2018. Our interactive training presentation will help you easily and succinctly explain MiFID II to staff affected by these changes.

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GDPR Fines

Since the General Data Protection Regulation (GDPR) came into effect in 2018, it has completely transformed how companies deal with their clients' personal data. It has introduced reforms that are tailor-made for today's world and promised severe consequences for any companies that fail to respect them.

Brexit has brought about change since UK data protection law has largely been governed by European Union law. However, from the 1st January 2021, the UK ceased to be a part of the EU, meaning that the EU GDPR no longer protects UK citizens. The general data protection regime that now applies to most UK businesses and organisations is theUK General Data Protection Regulation (UK GDPR), tailored by the Data Protection Act 2018.

Companies must report certain personal data breaches to the relevant supervisory authority within 72 hours of becoming aware of the breach.The maximum GDPR breach fine a company can face is 4% of their annual global turnover, or €20 million - whichever is the highest. For less serious violations, such as having improper records, there is a maximum of 2% of their annual global turnover, or €10 million.

Recent GDPR Fines

Here's a summary of the largest GDPR fines in 2019, 2020, 2021 and 2022:

Simple steps to avoid GDPR fines

At the core of the GDPR are seven key principles, which are laid out in Article 5 of the legislation and designed to guide how to handle people's data:

  • Lawfulness, fairness and transparency - be clear about the reason for collection and how the data will be used.
  • Purpose limitation - have a specific and legitimate reason for collecting and processing personal information.
  • Data minimisation - only store the minimum amount of data required for their purpose.
  • Accuracy - regularly review existing information about individuals and delete or amend inaccurate information accordingly.
  • Storage limitation - if there is no longer a need for personal data that aligns with the original purpose of collection, it should be deleted or destroyed unless there are other grounds for retention.
  • Integrity and confidentiality (security) - ensure that all the appropriate measures are in place to secure the personal data you hold.
  • Accountability - take responsibility for the data they hold and demonstrate compliance with the other principles.

Article 6 of the GDPR sets out the lawful basis for the processing of personal data.
At least one of these must apply whenever you process personal data:

  • Consent - The individual has given clear consent for you to process their personal data for a specific purpose.
  • Contract - The processing is necessary for a contract with the individual or because they have asked you to take specific steps before entering into a contract.
  • Legal obligation - The processing is necessary for you to comply with the law (not including contractual obligations).
  • Vital interests - The processing is necessary to protect someone's life.
  • Public task - The processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
  • Legitimate interests - the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual's personal data, which overrides those legitimate interests.

Free GDPR Training Resources

GDPR Personal Data Awareness Poster

All employees need to understand what personal data is and how to protect it. Our free GDPR Personal Data Awareness Poster details key personal data statistics and common misconceptions.

Free GDPR Personal Data Awareness Poster

GDPR Self-assessment Questionaire

Our comprehensive questionnaire contains 140 checks to help you assess your GDPR compliance effectiveness.

Free GDPR Self-assessment Questionnaire

GDPR Fundamental Awareness Aid

Your business and your employees need to be aware of the fundamental rights of GDPR. This is critical in ensuring GDPR compliance. Our awareness aid will help your employees understand GDPR rights, deadlines and the financial consequences that come with data breaches.

Free GDPR Fundamental Rights Poster

GDPR Training Presentation

Our free GDPR Training Presentation is fully editable, plainly presents the key points and is packed with practical activities to accelerate learning.

GDPR Training Presentation

Health & Safety Fines

Any breach in health and safety regulations is a criminal offence. The Health and Safety Executive (HSE) and local authorities are responsible for enforcing health and safety legislation in the UK. The HSE can issue notices of improvement or prohibition and financial penalties.

In the most severe cases where an employee's life is endangered or lost, authorities can impose prison sentences and unlimited fines. Injured employees can also claim against a business if the business fails to implement best practices.

Recent Health & Safety Fines

Here's a summary of the largest Health and Safety fines in 2019, 2020, 2021 and 2022:

Simple steps to avoid Health & Safety fines

In general, most health and safety-related fines handed out are due to the breach of section 2 of the Health and Safety at Work Act 1974. This act stipulates that an employer has to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all their employees. This duty involves:

  • Providing and maintaining safe equipment, machinery and systems of work.
  • Ensuring the safe use, handling, storage or transportation of articles or substances used at work or in connection with work by their employees.
  • Providing any information, instruction, training, and supervision necessary to ensure that employees can carry out their work safely.
  • Ensuring places of work are free from danger - premises under the employer's control must be free from danger, with safe means of entrance and exit.
  • Making sure the working environment is safe, without risks to health and providing adequate facilities and arrangements for welfare at work.

Free Health & Safety Training Resources

Workplace Stress Presentation

Workplace stress often stems from a lack of managerial support, tight deadlines and too much responsibility. Our interactive training presentation will help you educate your employees on the red flags of stress and how it can be alleviated.

Free Workplace Stress Training Presentation

Workplace Accidents Training Presentation

Our training presentation on workplace accidents will help your staff understand the importance of safety at work. It is also designed to highlight the responsibilities of both employer and employee concerning the Health and Safety at Work Act.

Free Workplace  Accidents Training Presentation

DSE Training Presentation

Repetitive keyboard use is one of the major contributing factors to work-related musculoskeletal disorders. Our interactive Display Screen Equipment (DSE) Training Presentation is designed to help your employees understand the risks associated with DSE. This presentation also outlines the measures they can take to help prevent any DSE related injuries whilst working.

DSE Training Presentation

More on Compliance Fines

As well as tracking the largest recent fines, we have also examined the largest penalties in history. We reflect on the biggest compliance fines in these key areas, from UK competition law fines to data breach fines and financial crime penalties.

We have searchable glossaries of key terms and definitions across the main compliance topics, including GDPR, Equality, Financial Crime and SMCR, to help you navigate these complex areas.

And finally, we explain what drives fines in specific areas and how to avoid them across financial sanctions, the GDPR and tax evasion.

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Compliance Bulletin

Compliance Bulletin

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