AML Analytics’ white paper examines two OFSI enforcement cases resulting in £4.89m in penalties against Citibank and Bank of Scotland for sanctions-screening failures and gaps in payment controls

Citibank processed 970 payments worth approximately £19.7m, while Bank of Scotland processed 24 payments totalling around £77,000. The cases also highlight weaknesses in account restrictions, ownership checks and frozen-asset reporting. The paper urges firms to test screening systems against name variations, cover the full payment chain and ensure timely escalation, restrictions and regulatory disclosures…