Question
What are the risk consequences arising from the issues highlighted in the regulatory report? The Bank has recently been the subject of a regulatory visit
What are the risk consequences arising from the issues highlighted in the regulatory report?
The Bank has recently been the subject of a regulatory visit and the report that followed has been highly critical of both the Board and the MLRO. Key criticisms included: A failure on the part of the MLRO to process internal Suspicious Activity Reports (SARs) and externalise them to the Financial Intelligence Unit (FIU) (26 in total with some as old as 18 months) The MLRO deliberately misled the Board into believing that money laundering was not a significant issue within the Bank. Tanya deliberately failed to notify the Board that Internal SARs had been made The Board of the Bank failed to meet regularly and did not monitor the internal AML reporting system and processes The MLRO was an extremely powerful individual and deemed unapproachable by members of staff The Bank prioritised business development over compliance From a corporate governance perspective, it was inappropriate for the MLRO to also control so many other areas of the bank's operations while carrying out the MLRO role.
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