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Release Date: 17th June 2020

To access the original FCA document, click here.


The Financial Conduct Authority (FCA) has fined Commerzbank AG (London Branch) £37,805,400 for failing to maintain adequate anti-money laundering (AML) systems and controls between October 2012 and September 2017. Despite being aware of these weaknesses, Commerzbank London did not take effective action to rectify them, even after the FCA raised specific concerns in 2012, 2015, and 2017.

The FCA’s investigation found several significant failings in Commerzbank London’s AML controls:

These failings breached Principle 3 of the FCA’s Principles for Businesses, which mandates that firms must have adequate risk management systems.

Mark Steward, Executive Director of Enforcement and Market Oversight at the FCA, emphasised the importance of robust AML controls for the integrity of the UK financial system. He noted that Commerzbank London’s prolonged failings significantly risked financial and other crimes going undetected.

Commerzbank London has since undertaken a significant remediation exercise to align its AML controls with regulatory requirements. A Skilled Person has tested the effectiveness of these enhancements, which are now complete. The bank also conducted an extensive review to identify suspicious transactions during the period in question and voluntarily implemented a wide-ranging business restriction, including halting new high-risk customer onboarding and suspending all new trade finance business activities.

Commerzbank London agreed to settle early in the investigation, qualifying for a 30% discount on the fine, reducing it from £54,007,800 to £37,805,400.

Key Takeaways:

In conclusion, the FCA’s action against Commerzbank London highlights the critical importance of effective AML systems and controls. Firms must prioritise robust AML measures to protect the integrity of the financial system and comply with regulatory expectations.

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