FCA fine CB Payments Limited £3.5m for failures in implementing voluntary restrictions

On 23 July 2024, The Financial Conduct Authority (“FCA”) issued a Final Notice and financial penalty of £3,503,546 to CB Payments Limited (“CBPL”) for multiple failures to comply with the Voluntary Application for Imposition of Requirement (“VREQ”) that CBPL had applied for on 30 October 2020. 

While it is rare to see fines issued to firms in the cryptoasset industry, the focus here relates to the gaps identified with the Firm’s systems and controls when implementing the VREQ. And although the penalty is not one of the longest that the FCA have published, it still provides valuable insights into the FCA’s expectations. The themes covered within this notice can be applied cross-sector (not just crypto) and across various areas of a compliance framework. Our gap analysis should help to condense some of the key findings.   

The notice predominantly focussed on systems and controls failures but also highlighted previous failures relating to Customer Risk Assessments, remediation of audit findings and overall Governance and culture failures at the Firm.   

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