On 7 August, 2003, the Financial Services Authority (FSA) fined Northern Bank £1.25m for breaches of its Money Laundering Rules – more specifically, for weaknesses in its customer identification procedures. The fine was the largest ever imposed for a money laundering breach. On 29 September, 2003, the National Criminal Intelligence Service published the fourth edition of its UK Threat Assessment, identifying money laundering as a fundamental component of serious and organised crime.

In the ongoing fight against financial crime and terrorism, the Northern Bank penalty sends out a clear message that the FSA is cracking down on those firms whose anti-money laundering systems and controls do not make the grade. The question is, how many more firms will fall foul of the anti-money laundering regime?