MLR1PP8350 - Penalties Guidance: The additional starting penalty for MSBs and HVDs

For MSBs and HVDs the additional starting penalty will be based on 20% of the amount that was potentially exposed to money laundering by the regulatory breaches. This amount is referred to in this guidance as the culpable turnover.

When calculating the additional starting penalty for a MSB or HVD, the following steps should be followed: