Penalties guidance: the basic principles of our penalty framework
The basic principles of the penalty framework are relatively simple:
We will calculate:
A total starting penalty - This will consist of a
- fixed starting penalty and
- an additional penalty determined by the amount potentially exposed to money laundering by the breach.
See MLR1PP8150 for more details
A penalty cap - The total starting penalty will be capped at 10% of the business’s Gross Profit (subject to a minimum of the fixed starting penalty in the case of HVDs/MSBs) to produce a maximum penalty figure.
See MLR1PP9150 and MLR1PP9160 for more details
- The Final penalty figure - Standard behaviour based percentage reductions may be applied to the maximum penalty figure to arrive at the final penalty figure. See MLR1PP10100 for these reductions.