On February 15, 2024, the Isle of Man Financial Services Authority levied a civil penalty of £1,008,337 (US$1.2 million) against the Royal Bank of Scotland International Limited (RBSI), a division of the Bank of Scotland. This penalty was imposed due to RBSI’s violation of paragraph 7 of the Anti-Money Laundering and Countering the Financing of Terrorism Code 2015.

Following an inspection conducted by the Isle of Man Financial Services Authority between June and July 2021, it was found that RBSI failed to promptly implement its updated Customer Risk Assessment process in accordance with the newly introduced Code. As a result, 2,239 non-personal customers onboarded between 2015 and 2018 lacked adequate documented Customer Risk Assessments, which did not comply with the requirements outlined in paragraph 7 of the Code. These customers were subjected to risk ratings based on outdated standards predating 2015 during this period.

In response to these regulatory findings, the Authority deemed it necessary for RBSI to pay a civil penalty of £1,440,481. However, this penalty was discounted by 30% to £1,008,337 under the Regulations and the Financial Services Act 2008.