FCA has fined ADM Investor Services International Limited, an investment broker, nearly £6.5m for inadequate AML systems and controls. The firm’s business model made it subject to high risks of money laundering, Its business involved customers in high risk locations, customers who were of themselves high-risk and it had PEPs among its clients. FCA had raised concerns with the firm in 2014, but found in a follow up visit in 2016 that significant failings remained. Among the failings were a lack of a firm-wide ML risk assessment, and a customer risk assessment that was too basic to allow assessment of the risks of financial crime the customer posed. Policies were outdated and there was little evidence of ongoing customer reviews.
After FCA’s 2016 visit, requirements were imposed on the firm, which were lifted in early 2018 after the firm put in place remedial measures.