The Financial Conduct Authority’s (FCA) fine of £37.8 million (U.S. $47.5 million) on Commerzbank’s London branch for anti-money laundering (AML) failures is a reminder that the most fundamental risk-based AML controls are still not being implemented at some financial services firms.
Weaknesses at Commerzbank London were identified by the FCA in a “number of areas.” These included the failure of the bank to conduct periodic due diligence on its existing clients in a timely fashion, resulting in nearly 2,000 overdue due diligence checks on existing clients by March 2017.

