Year: 2024

Walgreens to Pay $106.8 Million in Major Healthcare Fraud Settlement

Fraud, Prosecutions
Retail pharmacy giant Walgreens has agreed to pay $106.8 million to settle allegations of widespread fraud against government health care programs, the U.S. Department of Justice announced on Friday. The settlement resolves claims that Walgreens billed Medicare, Medicaid, and other federal health care programs for prescriptions that were never actually dispensed to patients. The alleged fraudulent activity spanned over a decade, from 2009 to 2020, during which Walgreens is accused of submitting false claims for payment, resulting in the company receiving tens of millions of dollars for prescriptions that were processed but never picked up by beneficiaries. Principal Deputy Assistant…

Mirabaud & Cie SA seriously violated financial market law

Money Laundering, Regulatory Fines
The Swiss Financial Market Supervisory Authority FINMA has found that Mirabaud & Cie SA breached its anti-money laundering obligations and seriously violated financial market law. FINMA determined this in enforcement proceedings. The bank failed to review and document sufficiently the economic background of client relationships and transactions. The bank may not accept any new clients with increased money-laundering risks until compliance with the law has been restored. Furthermore, FINMA has confiscated CHF 12.7 million of unlawfully generated profits and opened three proceedings against individuals.In June 2023, FINMA concluded enforcement proceedings against Mirabaud & Cie SA that were opened in June…

Danske’s France settlement ends final probe over suspected money laundering

Money Laundering, Regulatory Fines
COPENHAGEN (Reuters) -Danske Bank has reached a settlement with French authorities to end the final in a series of probes in multiple countries over suspected money laundering at its former branch in Estonia, the Danish bank said on Wednesday. Danske agreed to pay 6.33 million euros ($7.0 million) to settle an investigation in France, a fraction of the more than $2 billion it agreed to pay to end probes in the United States last year. The bank became the subject of several investigations after an internal probe in September 2018 uncovered about 200 billion euros of payments made through its…

Art Market Loopholes Again Threaten U.S. Economic Integrity and National Security

Art Market, Sanctions
Federal Indictment Charges Kremlin Allies with Money Laundering and Sanctions Evasion On September 5, the U.S. Department of Justice unsealed two criminal indictments charging dual U.S.-Russian citizens with multiple felonies for using art, antiques, and other methods to violate sanctions imposed after the 2022 illegal invasion of Ukraine—a scheme that also allowed the married couple to launder at least $1 million through the U.S. financial system. Dimitri and Anastasia Simes allegedly provided services to and received substantial benefits from sanctioned Russian individuals and entities, including Channel One Russia, the state-controlled television network, and oligarch Aleksandr Udodov. Anastasia, specifically, is charged…

Swedish Court Sends Ex-CEO of Swedbank to Prison

Money Laundering, Prosecutions
Overturning her previous acquittal, a Swedish court sent former Swedbank CEO Birgitte Bonnesen behind bars for 15 months for having made misleading, financially damaging statements about the bank’s poor anti-money laundering operations. An expert called the verdict of the Svea Court of Appeals “unprecedented.” The lower Stockholm District Court had cleared Bonnesen of all charges in January 2023. Following revelations in 2017–2018 that hundreds of billions of dollars could have been laundered through Danske Bank’s operations in the Baltics, Bonnesen was asked by reporters if Swedbank had similar problems with ties to that scandal. “The court concluded that two of…

Inside Hamas’ Pocketbook : Financing Terrorism through online financial platforms

Counter Terrorist Financing, Terrorism
In the wake of the 7 October attack and the war that has followed, Hamas, the Palestinian Islamic resistance movement, has conducted much of its financial activity through established and emerging online financial platforms (OFPs) to support its rule in the Gaza Strip. Even though Hamas is designated as a terror organisation (and is therefore sanctioned) in the US, UK, EU and elsewhere, it has been able to take advantage of compliance-related loopholes and poor counter-terror financing (CTF) practices OFPs suffer from. Some of the OFPs Hamas uses and abuses include technologies such as online payment processors, virtual assets service…

FCA charges first individual with running a network of illegal crypto ATMs

Prosecutions, Regulation
The FCA has charged Mr Olumide Osunkoya, who is 45 and resides in London, for unlawfully running multiple crypto ATMs without FCA registration. Crypto ATMs are machines that allow you to buy or convert money into cryptoassets. Mr Osunkoya is accused of running crypto ATMs, which processed £2.6m in crypto transactions across multiple locations between 29 December 2021 and 8 September 2023 without the required registration. The charges mark the FCA’s first criminal prosecution relating to unregistered cryptoasset activity under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs). These are also the…

Post-Soviet Union Elite’s Involvement in UK Money Laundering

Uncategorized
Dr Henry Balani, Global Head of Industry & Regulatory Affairs for Encompass Corporation comments: “Money laundering in the UK is a far more complicated an issue than one might expect, and there are thousands of unique and intricate relationships between UK finance professionals and international criminals which continues to contribute to the money laundering economy. Historically, London has been the centre of a vast physical empire that has now developed a financial powerhouse to support potential nefarious activities. Covid-19 and lockdown has certainly not helped either, as digital identity authentication and paperless transactions, for example, have made it easier for…

Money launderer jailed after extradition to UK

Money Laundering
A man who laundered more than £2m has been jailed after being extradited back to the UK. Calin Barta, 29, originally from Romania, was sentenced at Guildford Crown Court to four years and 10 months in prison. Three years ago, Surrey Police executed a warrant at an address in Woking as part of an investigation into indecent image offences. However, whilst at the property, officers said they found multiple mobile phones and bank card readers along with 38 passports in different names but all with the same photo. Barta returned to Romania while he was on bail, said police. Surrey’s…

Lack of City of London oversight hurting efforts to halt dirty money, FCA warns

Money Laundering
A lack of proper oversight across the City of London’s network of lawyers, bookkeepers and accountants is hampering efforts to crack down on dirty money being funnelled through the UK, the City watchdog has warned. The latest report by the Financial Conduct Authority (FCA) flagged concerns over the work of the UK’s 25 professional bodies – which oversee the accounting and legal sectors – and found that some were spending as little as £73 a year on anti-money laundering supervision or were outsourcing it entirely to third parties. It also found “weaknesses” in how bodies were using their powers, resulting…

UK announces new sanctions under Iran, Russia laws

Sanctions
LONDON, Sept 10 (Reuters) – Britain on Tuesday announced a new wave of sanctions, adding seven designations under its Iran sanctions regime and three under its Russia regime.Some of those sanctioned included firms and organisations with ties to the drone industries in Russia and Iran.The announcement came after U.S. Secretary of State Antony Blinken said Russia had received ballistic missiles from Iran and would likely use them in Ukraine within weeks.Alongside that announcement, made during a visit to Britain, Blinken said the U.S. would also impose new sanctions, including on airline Iran Air.France, Germany and Britain strongly condemned Iranian transfers…

Banks must refund fraud up to £85,000 in five days

Fraud, Regulation
UK banks must refund fraud victims up to £85,000 within five days under new rules. Most High Street banks and payment companies voluntarily compensate customers who are tricked into sending money to scammers. But in a world first, these refunds will become mandatory from 7 October, the Payment Systems Regulator (PSR) has announced. The watchdog has reduced the maximum compensation from a previous proposal of £415,000. It said the new cap of £85,000 would cover more than 99% of claims. It also announced that once a bank or payment company had refunded a customer, it could claim half back from…

DOJ’s New Whistleblower Program Faces Scrutiny from Legal Experts

Whistleblowing
The U.S. Department of Justice’s recently launched whistleblower reward program is drawing both praise and criticism from legal experts in the field. While many welcome the initiative, concerns have emerged about key aspects of the three-year pilot program. Introduced last week, the program offers financial incentives to individuals who provide original information or analysis related to financial crimes, bribery, or healthcare fraud. Deputy Attorney General Lisa Monaco announced the program in March, aiming to bridge gaps between existing whistleblower programs at other agencies. Legal professionals specializing in whistleblower cases have identified several potential shortcomings in the program’s structure: Funding Uncertainty:…

PwC Fined £15m for Fraud Alert Failures

Fraud, Prosecutions
PwC has been fined £15m for failing to alert the Financial Conduct Authority (FCA) to suspected fraudulent activity at London Capital & Finance (LCF). The FCA, which is fining an audit firm for the first time, said PwC encountered “significant issues” throughout its 2016 audit of LCF, with the company having and provided the Big Four outfit with “inaccurate and misleading information”. A senior individual at LCF also acted aggressively towards auditors. Considerably longer to complete According to the FCA, PwC found the audit very complex and it took “considerably longer to complete” than anticipated with the firm ultimately coming…

SEC Charges NovaTech and its Principals and Promoters with $650m Crypto Fraud

Digital Currencies, Fraud, Prosecutions
The Securities and Exchange Commission today announced charges against Cynthia and Eddy Petion, along with their company, NovaTech Ltd., for operating a fraudulent scheme that raised more than $650 million in crypto assets from more than 200,000 investors worldwide, including many in the Haitian-American community. The SEC also charged Martin Zizi, Dapilinu Dunbar, James Corbett, Corrie Sampson, John Garofano, and Marsha Hadley for their roles in promoting NovaTech to investors. According to the SEC’s complaint, the Petions operated NovaTech as a multi-level marketing (MLM) and crypto asset investment program from 2019 through 2023. They lured investors by claiming NovaTech would…

Whistleblowers Cash In: SEC Awards $98 Million for Crucial Tips

Whistleblowing
The Securities and Exchange Commission (SEC) has awarded a staggering $98 million to two whistleblowers. The announcement, made on August 23, 2024, underscores the critical role that individuals play in uncovering financial misconduct. The lion’s share of the award—$82 million—went to a whistleblower whose initial tip sparked the investigations and who provided ongoing assistance. A second whistleblower, contributing later but significantly to one aspect of the case, received $16 million. “Without these whistleblowers’ information, the violations would have been difficult to detect,” said Creola Kelly, Chief of the SEC’s Office of the Whistleblower, emphasizing the importance of such cooperation in…

Singapore Charges Ex-Bankers with Abetting $2.2 Bn Money Laundering Ring

Money Laundering, Prosecutions
Singapore charged two bankers Thursday for their alleged role in abetting clients responsible for a US$2.2 billion money laundering ring, marking the first time that criminal charges have been laid against finance professionals since the scandal came to light. The Central American Bank for Economic Integration (CABEI) has been trying to clean up its image after allegations of major mismanagement. But those efforts are now overshadowed by dueling lawsuits between the bank and its former president –– with each accusing the other of tarnishing their reputations. A former Georgian defense minister is under investigation for his alleged role in a…

Hong Kong Customs detects money laundering case involving about $1.5 billion

Money Laundering
Hong Kong Customs mounted an operation codenamed “Fencing” yesterday (August 7) and dismantled a money laundering syndicate receiving suspicious funds from the Asia-Pacific region. It was suspected that the syndicate masterminds and members made use of shell companies and cryptocurrency to launder crime proceeds amounting to about $1.5 billion. During the operation, Customs arrested four persons suspected to be connected with the case and has already arranged to freeze a total of about $2.2 million in assets held by the arrestees.      Earlier this year, Customs officers identified a money laundering syndicate for a financial investigation. It was revealed that the…

Investigation Goliath: Suspected ringleaders of international crime group charged with €93 million VAT fraud

Fraud, Prosecutions
Three suspected ringleaders of an international criminal group were indicted yesterday at the Regional Court of Dusseldorf (Germany) for a €93 million VAT fraud, following an investigation by the European Public Prosecutor’s Office (EPPO) in Hamburg, code-named Goliath. The three were charged with criminal association and VAT fraud on a large scale. Two of the defendants remain in pre-trial detention. One of the suspects was arrested during an action carried out by the EPPO on 22 November 2023, targeting the international criminal ring. Another suspect – a Danish citizen who had fled to Africa to escape detention – was arrested…

Gang jailed for operating £55m Chinese-money-laundering ring in UK

Money Laundering
Seven people have been jailed for operating an undercover £55m money-laundering ring aimed at international university students seeking to bypass limits on the amount of cash that can be taken out of China. Four people – three men and one woman – were sentenced at Snaresbrook crown court on Monday for a range of money-laundering offences. In June, three others were sentenced for similar offences. They were handed sentences ranging from 11 months to 12 years. Chinese citizens cannot transfer more than $50,000 (£38,000) for personal purposes out of the country a year. To regulate this, citizens are required to…

Property firm fined £22k for money laundering failures

Money Laundering
A property law firm in Manchester has been handed a fine of nearly £22,000 for failures in anti-money laundering (AML) procedures, towards the top end of the Solicitors Regulation Authority’s (SRA) powers. The fine represented 2.4% of the firm’s turnover, with the SRA acknowledging that “there was no evidence that actual harm had materialised”. According to an SRA notice, an inspection in early 2023 identified various areas of concern surrounding the firm’s compliance with the 2017 Money Laundering Regulations. This led to an investigation that found that GD Legal, which handles both residential and commercial property work, did not have…

Uptick in money laundering cases reaching UK courts, KPMG data shows

Money Laundering
There has been an increase in the number of alleged fraud cases heard in Crown Courts across the country, with money laundering being the most common fraud type by value in the last six months.According to new data by KPMG’s Fraud Barometer, 122 fraud cases in total were heard in the first six months of the year at the Crown Courts. This figure is up from 105 cases during the same period in 2023.Nine cases of money laundering, worth a collective £128.2m, have been heard so far this year.This increase comes on the back of a well-documented court system is…

US sanctions over 400 firms accused of aiding Russian war effort

Sanctions
The United States imposed new sanctions Friday on more than 400 entities accused of supporting Russia during its war with Ukraine. Announced the day before Ukraine’s Independence Day holiday, the sanctions focus on firms in Russia, Europe, Asia and the Middle East accused of helping Russia avoid U.S. sanctions and enabling its war in Ukraine, according to a Treasury Department press release. The Biden administration also added 123 firms to the U.S. export control list, which requires suppliers to obtain licenses prior to shipping items to the companies listed. Those added Friday included 42 Chinese firms and 63 Russian firms,…

Left steaming at the ears: father and son duo jailed after City of London Police uncover £136,000 iron fraud

Fraud
A father and son have been jailed for a total of five years after pocketing £136,000 in an elaborate scheme of purchasing reconditioned steam irons and returning them with forged receipts to Argos.Paul Mathews, 62, and Dean Mathews, 40, both of Queens Road, Wisbech, purchased heavily discounted Tefal steam irons, worth £400, and then returned them to Argos.Paul Mathews and Dean Mathews both pled guilty to conspiracy to commit fraud and money laundering and were sentenced to three years and two years, respectively, at Norwich Crown Court on 13 August 2024.The steam irons that were purchased by Paul and Dean…

Half of crypto ads on Facebook are scams or violate Meta’s policies, consumer regulator alleges

Fraud
More than half of cryptocurrency-related ads on Facebook analysed by Australia’s consumer regulator were scams or violated Meta’s policies, a court has heard. The Australian Competition and Consumer Commission (ACCC) took Meta to court over celebrity scam ads in 2022, alleging the company had engaged in false, misleading or deceptive conduct in publishing the ads, and aiding and abetting the false conduct by the advertisers. In a ruling issued last week, it was revealed the ACCC has alleged that, since at least January 2018, “Meta has been aware that a significant proportion of cryptocurrency advertisements on the Facebook platform have…

Eurojust supports large-scale anti-mafia operation leading to arrest and freezing of EUR 50 million

Money Laundering
An investigation lasting over two years has uncovered an intricate money laundering scheme run by a mafia family from Palermo. The total value of their profits is estimated at over EUR 500 million. They reinvested the profits of their crimes in multiple companies in Brazil. Cooperation between Italian, Brazilian and Swiss authorities led to the arrest of a member of the organised crime group (OCG) during an action day on 13 August, as well as the freezing of financial assets worth EUR 50 million during several searches in Italy, Brazil and Switzerland.To support other major mafia families, the OCG was…

Unraveling the Web: Money Laundering through E-Payments from Russia to the UK

Money Laundering
Experts from Transparency International Russia (in exile) have conducted an in-depth analysis of illegal money transfers from Russia to the UK through e-payments over the past decade.This research examines the sophisticated trade of verified business bank accounts, often exploited by criminals to obscure large-scale financial transfers. The investigation highlights significant regulatory gaps and the use of dark web marketplaces where these accounts are sold, often registered under false identities with genuine documents. The study reveals that high-risk profiles, including politically exposed persons (PEPs and complex corporate structures exacerbate these risks.The report identifies several e-payment platforms, which have been exploited for…

Man charged over €6.5m cryptocurrency seizure in Dublin

Digital Currencies, Money Laundering
A man has appeared in court following the seizure of €6.5m (£5.6m) worth of cryptocurrency in County Dublin.The seizure was part of an investigation into the sale of illegal material on darknet markets and money laundering.The 23-year-old man is facing three counts of money laundering.Two other people arrested as part of the police investigation, a 49-year-old man and a 32-year-old woman, have been released from custody. As part of the investigation, the Garda National Cyber Crime Bureau (GNCCB) said they seized “substantial assets” including Bitcoin and Monero, along with watches worth €120,000 (£100,000) and two vehicles valued at €220,000 (£190,000).Kevin…

Illinois judge orders $120 million payment in crypto fraud case

Digital Currencies, Prosecutions
An Illinois district judge has ruled in favor of the U.S. Commodity Futures Trading Commission (CFTC), ordering Oregon resident Sam Ikkurty and his company Jafia, LLC to pay over $120 million, partly in restitution, to victims of what the CFTC described as a “Ponzi”-like scheme. Judge Mary Rowland of the U.S. District Court for the Northern District of Illinois issued the opinion on Monday, which was posted by the CFTC on Wednesday. The ruling stated that Ikkurty and Jafia made “material misrepresentations” and engaged in fraud without proper registration. In a notable part of the order, Judge Rowland classified cryptocurrencies…

SEC hands out $37 million to whistleblower

Whistleblowing
The Securities and Exchange Commission has awarded a whistleblower with $37 million for providing new and critical information that led to the success of an enforcement action. According to the agency’s order, one whistleblower received the regulatory bounty for information and assistance that led the staff to open the investigation into “hard-to-detect violations.” He was the initial source that alerted the SEC to a previously unknown conduct and thereafter provided assistance that helped advance investigations. Specifically, he gave useful information at the earliest stages of the investigation and later provided supplemental information. Committed to protecting the anonymity of informants, neither…

U.K. Crime Agency Asks Court to Permanently Seize Russian Oligarch’s Money

Proceeds of Crime
Britain’s National Crime Agency has for the first time asked a court to permanently seize funds held by a Russian oligarch, arguing that they are “proceeds of crime,” because he allegedly moved the money in violation of sanctions regulations.The agency, known as the NCA, applied on May 1 for a forfeiture order for 1.1 million British pounds (US$1.4 million) from Petr Aven, a billionaire who the U.K. says has “been involved in supporting the Government of Russia” during its war in Ukraine.The money has been frozen since the U.K. sanctioned Aven in 2022. The NCA believes it has now gathered…

Federal Reserve & California Regulators Levy $63 Million in Penalties Against Silvergate for Anti-Money Laundering Violation

Uncategorized
The Federal Reserve Board and California’s Department of Financial Protection and Innovation (DFPI) have imposed a combined $63 million in penalties on Silvergate Capital Corporation and its subsidiary, Silvergate Bank, for inadequate transaction monitoring in violation of anti-money laundering (AML) laws. The announcement, made on Monday, July 1, 2024, comes as part of a coordinated effort between federal and state authorities. The penalties break down as follows: $43 million fine from the Federal Reserve Board$20 million payment to the California DFPI$50 million in penalties assessed by the U.S. Securities and Exchange Commission (SEC), offset by the payments to the Federal…

U.S. is seizing Los Angeles mansion from family of Armenian politician accused of bribery

Bribery, Prosecutions
The U.S. is seizing a more than 30,000-square-foot Los Angeles mansion from the family of an Armenian politician, a sprawling estate on the Westside which federal prosecutors allege was paid for with millions of dollars in bribes. The home belonging to the family of Gagik Khachatryan is situated in LA’s Holmby Hills neighborhood, wedged between Beverly Hills and Bel Air, and was estimated by U.S. prosecutors to be worth $63.5 million in May 2022. An updated estimated value of the home was not given Monday. But the American government will sell it off for the “highest obtainable market price” and…

FATF Updates High-Risk and Monitored Jurisdictions List, Reshaping Global Financial Landscape

FATF, FinCEN
The Financial Crimes Enforcement Network (FinCEN) has announced significant changes to the Financial Action Task Force’s (FATF) list of jurisdictions with strategic deficiencies in their anti-money laundering, counter-terrorist financing, and counter-proliferation financing (AML/CFT/CPF) regimes. These updates, stemming from the FATF’s June 2024 plenary meeting, are poised to have far-reaching implications for the global financial system and U.S. financial institutions. In a notable shift, the FATF has added Monaco and Venezuela to its “Jurisdictions Under Increased Monitoring” list, commonly referred to as the “grey list.” This designation indicates that both countries have acknowledged deficiencies in their financial crime prevention systems and…

Spanish Court Asked to Fine Duro Felguera €160M in Venezuela Alleged Bribery Case

Bribery, Prosecutions
Spanish anti-corruption prosecutors have asked a court to impose a fine of 160 million euros ($173 million) on the engineering and construction company Duro Felguera S.A., which they allege bribed Venezuelan officials in return for securing a contract to build a power plant.Prosecutors have also requested prison sentences and fines for two of Duro Felguera’s previous presidents, as well as Nervis Villalobos, Venezuela’s former energy vice-minister, according to an indictment seen by OCCRP.“All the commissions paid by ‘Duro Felguera’ were aimed at ensuring the company was privileged both in the awarding of the construction of the thermoelectric power plant and…

U.S. Financial Regulators Propose Sweeping Changes to Anti-Money Laundering Rules

Money Laundering, Regulation
On July 19, 2024, a coalition of U.S. financial regulators unveiled a comprehensive proposal to overhaul anti-money laundering (AML) and countering the financing of terrorism (CFT) regulations for banks and other financial institutions. This joint initiative, led by the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury, along with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC), represents the most significant update to AML/CFT rules in decades. The proposal aims to modernize the…

FinCEN Intensifies Efforts to Combat Fentanyl Trafficking & Money Laundering

Drug Trafficking, Money Laundering
The Financial Crimes Enforcement Network (FinCEN) has launched a comprehensive initiative to tackle the twin threats of fentanyl trafficking and money laundering, highlighting the critical role of financial intelligence in combating these interconnected crises. This effort, part of the broader Counter-Fentanyl Strike Force led by the Treasury Department, aims to disrupt the financial networks fueling the devastating opioid epidemic across the United States. At the heart of this initiative is the “Promoting Regional Outreach to Educate Communities on the Threat of Fentanyl” (PROTECT) series, a set of ten planned events across U.S. cities most impacted by the opioid crisis. These…

FCA takes first enforcement action against firm enabling cryptoasset trading

Regulatory Fines
CB Payments Limited (CBPL) has been fined £3,503,546 by the Financial Conduct Authority (FCA) for repeatedly breaching a requirement that prevented the firm from offering services to high-risk customers. CBPL is part of the Coinbase Group, which operates a prominent cryptoasset trading platform that is accessible globally. CBPL does not undertake cryptoasset transactions for customers but it acts as a gateway for customers to trade cryptoassets via other entities within the Coinbase Group. CBPL is not currently registered to undertake cryptoasset activities in the UK. The firm entered into a voluntary requirement (the VREQ) in October 2020, which followed significant…

UK – HMRC criminal investigation into alleged exports of perfume to Russia

Sanctions
In a civil judgment handed down earlier this week, it was revealed (at paragraph 63) that an individual, David Crisp, was arrested by HMRC on 10 October 2023 and electronic devices were seized. The allegation is that companies managed by Mr Crisp were knowingly exporting perfume to Russia in breach of the UK’s sanctions. As of the date of the judgment, HMRC had confirmed (at paragraph 69) that the criminal investigation remains ongoing but so far no charges have been made and Mr Crisp is no longer on bail. The judgment itself is of note for the Court removing Mr…

FCA calls on firms to improve treatment of politically exposed persons (PEPs)

Money Laundering
The FCA has told financial firms – including banks, payment firms and lenders – to do more to ensure parliamentarians, senior public servants and their families are not treated unfairly. Under legislation adopted by Parliament, financial firms are required to do extra checks on so-called politically exposed persons (PEPs). This follows global standards set by the international Financial Action Task Force and implemented by more than 200 jurisdictions. There have been concerns about how firms in the UK are meeting these requirements and so the FCA has reviewed how firms are treating PEPs. The FCA found that most firms in…