Penalties guidance: the additional penalty and different business sectors: continued
The additional penalty for TCSPs/ASPs/EABs will therefore be calculated using standard scale charges determined by the number of relevant customers or clients who may have exposed the TCSP/ASP/EAB to money laundering, as a result of its breaches.
Some of the products or services TCSPs/ASPs/EABs offer may fundamentally be high risk or some of their clients may be high risk. Factors such as a failure to identify these risks by the business together with a poor compliance history and an absence of suspicious activity reporting could be indicative of money laundering.
Under these circumstances a criminal investigation should be considered. See MLR1PP12160
If there is no suspicion of money laundering but there are serious breaches where either TCSPs/ASPs/EABs have provided services to high risk businesses or large amounts of money are involved, consideration should be given to suspending the penalty framework. See MLR1PP7150 and MLR1PP12050