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Enforcement Watch Roundup

Issue 32: September 2020

Enforcement Watch Roundup
Adam Epstein Post

Editor's Note

This edition of Enforcement Watch sees a broad range of enforcement cases, throwing up an interesting mix of issues, as well as one or two things on the horizon. Although quite what the future holds in the current climate is somewhat difficult to predict. We hope you enjoy it.

Enforcement Case Highlights


FCA Substantial Fine for Failures in Mortgage Arrears Handling

The FCA has fined three subsidiaries of Lloyds Banking Group, namely Lloyds Bank, Bank of Scotland and The Mortgage Business ("the Banks") £64 million, after a 30% settlement discount, for breaches of Principles 3 (management and control) and 6 (customers' interests) of the FCA Principles for Business.


FCA Fine for Anti-Money Laundering Failings

The FCA has fined Commerzbank AG, London Branch ("Commerzbank") £37,805,400 for failing to put adequate anti-money laundering ("AML") systems and controls in place between October 2012 and September 2017 (the "Relevant Period").

On the Horizon


FCA Reflections: Client Assets and Money

Megan Butler, the Executive Director of Supervision – Investment, Wholesale and Specialists at the FCA, delivered a speech at PIMFA’s Virtual Festival in June 2020 in which she stated that, "the preservation of client assets and money is central to our focus in the wealth management sector".

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