Coutts fine for PEPs and AML failings for me highlights again the extent to which intelligence led due diligence is still not being considered by FS firms and perhaps more importantly the disconnect that still remains between compliance functions and the business side of firms.

The compliance function needs to show the business that requiring ongoing information as part of an institution's policy/regulatory risk mitigation obligations (whether it is for ABC, AML or sanctions), can also be opportunity for the business- knowing your customer does not just mean taking a copy of their passport but also understanding what their plans for the future are and where potential opportunities may be.