MLR1PP10500 - Penalty Guidance: Relative seriousness of deliberate breaches

Even if the breaches are deliberate, a reduction of 10% will still be allowed if the consequences of the breaches, in terms of size and gravity, are not in absolute terms the most serious. For example, failure to train some staff or conduct ongoing monitoring on low risk customers, despite previous warnings, will normally be viewed as less serious than failing to implement any of the fundamental requirements listed in MLR1PP7300 

The decision whether to allow the 10% reduction for less serious deliberate breaches will depend on the specific circumstances and reasons for the breach. Compliance Officers will adopt a risk based approach when considering these circumstances.

• (This text has been withheld because of exemptions in the Freedom of Information Act 2000)