The Irish Central Bank has imposed a €5.9 million fine on Wells Fargo Bank International Unlimited Company for breaches of regulatory reporting and governance requirements under CRD IV, as implemented in Ireland.
The fine followed a thematic review of internal processes, controls and governance of regulatory reporting. This review found a number of systemic failings, including accusations of weak governance arrangements, specifically lack of a robust Board and senior management oversight, inadequate internal control mechanisms and weaknesses in IT systems. The Central Bank noted as evidence of the failure of these controls the fact that the bank itself did not detect the non-compliance.
This fine is a timely reminder of both the importance of ongoing reviews of internal governance arrangements, and that, if a breach occurs, it is better that the firm discovers it, and notifies the regulator, rather than being notified of such by a regulator.