The failures listed included:
(1) Failure to file SARS timely.
(2) Banks failing to identify new customers prior to opening accounts, or providing services.
(3) Failure to perform existing customer due diligence remediation, where necessary.
(4) Failure to provide AML and CFT training to staff members.
(5) Failure to allocate resources necessary to implement changes necessary to comply with 2010 AML/CFT laws.