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Release Date: 10th May 2013

To access the original FCA document, click here.


J.P. Morgan International Bank Limited (JPMIB) has been fined £3,076,200 by the Financial Conduct Authority (FCA) for failing to maintain adequate systems and controls in its wealth management business. This fine is a result of deficiencies in JPMIB’s provision of retail investment advice and portfolio investment services, which persisted over two years and were only addressed following the FCA’s thematic review into the suitability of advice offered by wealth management firms.

Key issues identified by the FCA included outdated client files lacking crucial suitability information such as client objectives and investment experience, and a record-keeping system that was insufficient for retaining necessary client details. Additionally, JPMIB was found to have failed in providing adequate suitability reports and communications required by its own policies. This lack of robust controls and monitoring meant that there was a significant risk of clients receiving incorrect advice or inappropriate investments.

Despite these failings, no direct detriment to customers has yet been identified. Nevertheless, the situation highlighted significant gaps in JPMIB’s internal oversight and risk management processes. The FCA’s intervention led to JPMIB appointing a Skilled Person to thoroughly assess and enhance its systems and controls, implementing recommendations, and overhauling its processes for assessing client suitability.

This case underscores the crucial importance for financial institutions to maintain complete and updated client records and to ensure that their management is equipped to recognise and rectify compliance failures promptly. The FCA stresses that all wealth management customers should expect firms to manage their affairs with adequate diligence to safeguard against unsuitable financial advice. The enforcement action against JPMIB serves as a reminder and warning to other firms about the regulatory expectations and the need to adhere strictly to compliance norms to prevent similar punitive measures.

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