The regulator said that the bank had failed to keep proper records of customer identification as required by the rules following an investigation of controls across its retail, corporate and business banking divisions.
The bank had failed to retain either a copy of the customer identification evidence or a record of where the evidence could be obtained, a situation made worse by the bank’s inability to determine the areas in which the breakdown in its record keeping systems had occurred, the FSA said.
Since the failings were discovered the Bank of Scotland implemented an action plan across the whole of HBOS Group, which significantly improved compliance rates and the FSA is now satisfied that the bank ahs dealt with the issues for which it was fined.
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