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DECISION NOTICE: Turkish Bank (UK) Ltd

In 1993-94, when the “Socialist Market Economy” policy encouraged a new wave of reform, fiscal reforms were put in place to clarify fiscal revenues and responsibilities, and it included three components: a tax-sharing system, tax modernization, and a reform of tax administration that separated central and provincial tax collection. The new tax- sharing arrangements allocated certain sources of revenues to the center (e.g., customs duties, consumption tax, sales tax, and profit taxes from centrally-controlled enterprises), to the provinces and municipalities (taxes on local enterprise income, house and property taxes, profit turnover taxes) and shared according to a predetermined ratio (the. | Financial Services Authority DECISION NOTICE To Turkish Bank UK Ltd FSA ref. no. 204566 Date 26 July 2012 TAKE NOTICE that the Financial Services Authority of 25 The North Colonnade Canary Wharf London E14 5HS has decided to take the following action 1. ACTION 1.1. For the reasons given in this Notice and pursuant to regulation 42 of the Money Laundering Regulations 2007 the ML Regulations the FSA has decided to impose on Turkish Bank UK Ltd TBUK or the Firm a civil penalty of 294 000 for breaches of the ML Regulations in relation to the Firm s anti-money laundering and counter terrorist financing AML controls over its correspondent banking activities in the period between 15 December 2007 and 3 July 2010 the Relevant Period . 1.2. TBUK agreed to settle at an early stage of the FSA s investigation. It therefore qualified for a 30 Stage 1 discount under the FSA s executive settlement procedures. Were it not for this discount the FSA would have imposed a financial penalty of 420 000 on TBUK. 2. SUMMARY OF REASONS 2.1. For more than two and a half years TBUK breached the ML Regulations by failing to 1 establish and maintain appropriate and risk-sensitive AML policies and procedures for its correspondent banking relationships 2 carry out adequate due diligence on and ongoing monitoring of the Firm s 1 customers acting as respondent banks in TBUK s correspondent banking relationships the Respondent s and reconsider these relationships when this was not possible and 3 maintain adequate records relating to the above. 2.2. These breaches gave rise to an unacceptable risk that TBUK could have been used to further money laundering. The Firm s Respondents were from jurisdictions Turkey and Northern Cyprus which did not have UK-equivalent AML requirements in place in the Relevant Period. In addition correspondent banking poses a high risk of money laundering and 114.48m flowed through TBUK s correspondent banking accounts in the Relevant Period to which TBUK did not apply the