The Financial Services Authority (“FSA”) has fined Coutts & Company (“Coutts”) £8.75 million for failing to take reasonable care to establish and maintain effective anti-money laundering (“AML”) systems and controls relating to high risk customers, including Politically Exposed Persons. The failings at Coutts were serious, systemic and were allowed to persist for almost three years.  They resulted in an unacceptable risk of Coutts handling the proceeds of crime. In October 2010, the FSA visited Coutts as part of its thematic review into banks’ management of high money-laundering risk situations.  Following that visit, the FSA’s investigation identified that Coutts did not apply robust controls when starting relationships with high risk customers and did not consistently apply appropriate monitoring of those high risk relationships.  In addition, the FSA determined that the AML team at Coutts failed to provide an appropriate level of scrutiny and challenge.