Regulatory gap analysis: FCA fines Mako Financial Markets £1.6m for financial crime failures

The FCA has marked the closure of its investigation into the cum-ex trading scandal by issuing an eighth Final Notice to Mako Financial Markets Partnership LLP.

Mako was fined over £1.6 million for financial crime failures, specifically relating to its management of customer risk through third parties, deficient due diligence processes and inadequate transaction monitoring arrangements. The firm executed a number of purportedly fraudulent trades between December 2013 and November 2015 and did not act with due skill, care and diligence in maintaining and applying adequate AML policies and procedures.

The FCA highlighted that despite it being acknowledged that the customer base posed an increased financial crime risk, in the MLRO report at the time, actions taken to manage or mitigate said risks could not be evidenced.

Our gap analysis is linked below. Go through the self-assessment questions and really challenge yourselves on the adequacy of your controls against Regulator’s expectations.

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