This is the first time the FSA has fined a money laundering reporting officer.
The FSA found a number of failings including:
- the firm failed to implement adequate procedures for verifying the identity of its clients;
- it failed to verify adequately the identity of a significant number of its clients;
- it failed to keep adequate records with regard to the verification of the identity of its clients; and
- Mr Wheelhouse failed to take reasonable steps to implement adequate procedures for controlling money laundering risk.
William Amos, head of retail enforcement at the FSA, said: "It is vital to the integrity of the UK’s financial markets that regulated firms are not used by criminals to launder money. Senior management must implement and follow procedures that meet our requirements so that the risks their firms face are properly managed.
"This fine is a warning to firms and individuals about the importance of complying with our rules in this area and we will not hesitate to clamp down on failures, where necessary."
In deciding the penalty for SHL, the FSA took into account the limited financial resources of the firm and its ability to pay the fine. Had it not been for these factors the penalty would have been significantly larger.
SHL and Mr Wheelhouse have taken robust steps to review and improve the firm’s systems and controls in relation to financial crime.
The FSA did not find any evidence of money laundering at the firm.
