Partner Anna Bradshaw comments on the causes of the increases in the fines imposed for anti-money laundering failures during the first half of this year, in excess of the total imposed for the whole of 2019.  She agrees that these include a lack of resourcing and system upgrades. “This would be consistent with our experience in practice”, says Anna Bradshaw. “The root cause is always a lack of resources. AML resources are either not sufficient, or they are not allocated efficiently”. Noting the drop in AML fines imposed in the US this year compared to 2018, Anna Bradshaw points to the increased enforcement activity elsewhere, in particular the EU. “The increase in non-US fines will also reflect new powers, such as the French deferred prosecution agreements first deployed for AML failings by HSBC Private Bank in 2017 and more recently for AML failings by the Bank of China Limited”, she says; adding that heightened European enforcement activity may also have been motivated by a desire to “fend off more damaging US attention”. Read more