Comparison with other fines

It is hard to draw many lessons from the size of the fine, except to speculate that the FCA might be slightly tougher in its fining than the old FSA. The period in which Guaranty Trust Bank made its mistakes – between 19 May 2008 and 19 July 2010 – was roughly the same as Turkish Bank's period – between 15 December 2007 and 3 July 2010, so the same fining rules ostensibly apply. The vast majority of misconduct in both cases came before the introduction of the FSA’s new penalty regime on 6 March 2010.

Turkish Bank UK's fine, however, was only £294,000 despite the fact that its conduct seems to be more egregious - at no point has the FCA accused Guaranty Trust Bank of designating its parent country's woeful anti-laundering efforts as 'equivalent' to the European Union's in the way that Turkish Bank UK did with Turkey's. On the other hand, the Turkish Bank fine - doled out in July last year – represented one of the opening shots in the FSA's drive to stop London boutique banks for HNW individuals from classifying country risk in any way that suited their customer-bases and the FCA doubtless believes that it can get away with more now that it has established its principle.