Tuesday, April 21, 2015

FCA £2.1m FINE OF LEBANESE BANK, ITS COMPLIANCE OFFICER AND INTERNAL AUDITOR NOT WELL KNOWN OUTSIDE UK



The fact that Britain's Financial Conduct Authority (FCA) levied a multi-million Pound fine on the Bank of Beirut's UK subsidiary, Bank of Beirut (UK) Ltd., and also fined the bank's compliance officer, and its internal auditor, does not seem to have been heard in North America. I have failed to find any significant coverage in the compliance press, which is disturbing, because the Bank, which had been ordered years ago to clean up its act, nor only dragged its feet, but misled the regulators, time and time again, about the status of its mitigation of the problems. It "failed to be open and cooperative" with the regulator, and notes in the report indicated that pressure from senior management weighed heavily upon the two bank officers fined, but it did not excuse their actions.

I recommend that US & Canadian compliance officers review the Final Notice, the complete text of which can be accessed here*. The bank failed to implement and conduct an adequate compliance monitoring program, failed to meet deadlines, and gave false assurances that the work have been completed, all exposing the bank to financial crime.


The bank has been ordered not to accept any new clients from high-risk jurisdictions, as the same are defined by Transparency International's guidelines.

Lastly, the fine assessed was really £3m, but the FCA gave a 30% discount for settlement purposes.

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*Final Notice 2015:Bank of Beirut (UK) Ltd.

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