Release Date: 13th July 2023
To access the original FCA document, click here.
Summary
Bastion Capital London Limited has been fined £2,452,700 by the Financial Conduct Authority (FCA) due to serious failings in its anti-money laundering (AML) systems and controls. These failings exposed the firm to significant risks of being used for fraudulent trading and money laundering activities, particularly in relation to business conducted with the Solo Group.
Reasons for the Fine:
- Inadequate Systems and Controls: Bastion did not have effective systems and controls to identify and mitigate risks of financial crime.
- Failure to Exercise Due Skill, Care, and Diligence: The firm did not properly apply AML policies, failing to adequately assess, monitor, and manage the risk of financial crime.
- High-Risk Transactions: Bastion executed suspiciously high-value equity trades and uneconomic transactions that were highly suggestive of financial crime, involving the Solo Group and their clients.
Key Takeaways for Other Firms:
- Implement Robust AML Systems: Ensure effective systems and controls are in place to identify and mitigate financial crime risks.
- Conduct Thorough Due Diligence: Properly assess and document the risks associated with clients, especially those from high-risk jurisdictions.
- Ongoing Monitoring: Continuously monitor transactions to identify and investigate unusual or suspicious activities.
- Recognise Red Flags: Be vigilant and responsive to indicators of potential financial crime, ensuring prompt action is taken.
- Comprehensive Policies and Procedures: Develop and maintain detailed AML policies and procedures that are proportionate to the risks associated with the business.
Conclusion:
The FCA’s action against Bastion Capital London Limited underscores the critical importance of robust AML systems and vigilant risk management. Financial firms must ensure compliance with regulatory standards to protect against financial crime and maintain the integrity of the financial system.