The AML Analyst

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  • The FCA’s Sanctions Review: Strong Controls Mean Nothing Without Governance and Oversight

    June 2nd, 2026 On May 28th, 2026, the FCA published its review of 150 supervised firms across a range of financial services sectors, assessing their sanctions systems and controls related to financial and trade sanctions. The FCA’s findings reveal a gap in governance and oversight of the overall sanctions framework. One of the areas the FCA investigated was Management Information…

  • Deutsche Bank’s Sanctions Breach Exposes the Risks of Downstream Customer Oversight

    May 28th, 2026 On May 19th, 2026, the Office of Financial Sanctions Implementation (OFSI) fined the London office of Deutsche Bank £165,000 for processing two payments totalling £635,618.75 on behalf of a client to their beneficiary Okko, a company owned by Russian-sanctioned entity JSC New Opportunities.  What stands out in this case is that Okko itself wasn’t Deutsche’s client, but…

  • The FCA’s CDD Review Reveals a Culture Problem. Not a Knowledge Problem

    May 26th, 2026 On the 8th of April, the FCA released its 2025 multi-firm review of Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and ongoing due diligence reviews. The reviews focused on firms’ approaches to: Policies and Procedures, CDD Processes, and Compliance Monitoring and Audit. The FCA’s findings reveal that firms understand the regulations, but are failing to embed…