A broker affiliate of Archer Daniels Midland was ordered to pay nearly 6.5 million pounds (U.S. $7.9 million) by the U.K. Financial Conduct Authority (FCA) for not timely addressing anti-money laundering (AML) systems and controls deficiencies first alleged by the regulator in 2014.
London-based ADM Investor Services International (ADMISI) avoided a penalty of more than £9.2 million (U.S. $11.1 million) in the case by not disputing the agency’s findings and cooperating with its investigation, the FCA announced in a press release Monday.
The details: The FCA said it expected ADMISI to address concerns it raised regarding the firm’s AML systems during a 2014 periodic assessment. Specific issues the regulator said it found involved the firm’s risk management framework, compliance monitoring, and client risk assessment, according to the FCA’s final notice.
When the FCA visited again in 2016 to assess the adequacy of ADMISI’s AML systems and controls, it found “some inadequacies remained from the 2014 assessment,” including regarding the design and implementation of the firm’s client risk assessment matrix, per the notice.
ADMISI did not conduct a firm-wide money laundering risk assessment, showed little evidence of ongoing customer monitoring, and relied on outdated policies, according to the FCA.
Compliance considerations: After the 2016 visit, ADMISI voluntary agreed to limit higher risk aspects of its business until its systems and controls were adequate. By October 2016, the firm had in place a suite of AML policies and procedures that was clear and covered the areas the FCA expected, the regulator noted.
The voluntary limits the firm agreed to were lifted in January 2018.
In its notice, the FCA acknowledged its findings regarding the firm’s failures were historic and that ADMISI engaged with external compliance consultants to enhance its systems. The regulator said there was no evidence any money laundering or financial crime resulted from the firm’s shortcomings.
Firm response: “While no actual harm was identified, ADMISI recognizes that the systems in place to mitigate [AML] risks during this period (September 2014 and October 2016) fell short of the expected standards,” the firm said in an emailed statement. ADMISI has since hired a new compliance director and finance director and appointed a specialist money laundering reporting officer.
“ADMISI is pleased that the issue has been resolved and is confident in the actions put in place to meet all regulatory requirements,” the firm said.