FSA fines and enforcement actions in 2004

The FSA fined The Governor and Company of the Bank of Scotland £1,250,000 on 12 January 2004 for widespread failures in keeping customer identification records. A 2002 internal review found a 55% failure rate across the Retail, Corporate and Business divisions; the FSA’s investigation concluded the bank breached ML 7.3.2 (firms must retain a copy of customer identification evidence or a record of where it can be obtained) and ML 2.1.1 (firms must set up and operate arrangements to ensure they comply with the Money Laundering rules). The FSA noted the failings dated back at least to 2000, accepted that the bank promptly implemented remedial plans and co‑operated with the investigation, and said those factors reduced the size of the penalty.