Compliance officers in the financial sector, beware: If you tell the Financial Conduct Authority in Britain that you have adequate internal controls and systems in place, be absolutely certain that is the case. 

Deutsche Bank and its British subsidiary, DB Group Services, learned that lesson the hard way last month, when the FCA slapped the bank with a £226.8 million ($345.6 million) penalty for the bank’s role in manipulating the London Interbank Offered Rate (LIBOR). The fine was part of a $2.5 billion global settlement that Deutsche Bank reached with other enforcement authorities. 

Jaclyn Jaeger is a freelance contributor to Compliance Week after working for the company for 15 years. She writes on a wide variety of topics, including ethics and compliance, risk management, legal,...