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Reviews into customer account closures

28 Jul 2023

NatWest Group (“the Group”) has appointed the law firm Travers Smith LLP (“Travers Smith”) to undertake a thorough and independent review into the account closure arrangements at Coutts. The review will identify lessons to be learned and, where appropriate, recommend areas for improvement.

The Travers Smith review will be carried out in two phases as set out below. Travers Smith will have appropriate unfettered access to relevant NatWest Group records and staff in the conduct of their review.

The key findings of the review and any recommendations will be considered by the Group Board and the findings and the steps the Group will take in response will then be made public.

The findings of Phase 1 can be found in the Travers Smith Phase 1: Key Findings & Recommendations report

The findings of Phase 2 can be found in the Travers Smith Phase 2: Key Findings & Recommendations report

Terms of Reference

Phase 1 

1. External Review of the decision to close the accounts of Mr. Farage. Travers Smith will:

a) Review Coutts’ policies and processes in relation to customer account closures and how these were applied in relation to Mr. Farage;

b) Review how Mr. Farage’s account was identified for closure and the steps that led to his case being considered by the Wealth Reputational Risk Committee;

c) Review the decisions made at different stages of the process and the documentation that was produced to support those decisions (including minutes of various meetings). This review will include consideration of the decision as to whether to offer Mr. Farage alternative NatWest Group banking facilities;

d) Review whether those decisions were taken in accordance with the relevant bank policies and processes;

e) Review the communication of the decision to Mr. Farage; and

f) Review the actions and roles of senior executives and the board at each of Coutts and NatWest Group level, including the timing and content of updates they were given.

2. Review the circumstances surrounding the BBC article and if any leak of confidential customer information or breach of GDPR occurred. Travers Smith will:

a) Consider whether any briefings with the media (including the BBC) took place during the relevant times, and whether there was any senior executive involvement in such briefings;

b) Review how the NatWest Group responded to the possibility of confidential information leaving the organisation and the actions that were taken. 

Phase 2

3. Review of Coutts’ account closures over the preceding 24 months.

Informed by the conclusions of Phase 1 above, Travers Smith will review the relevant standards that have been applied when recommending the closure of customer accounts at Coutts, including regulatory guidance around Political Exposed Persons (“PEP”), equalities legislation and any other relevant legal/regulatory guidance.

This will be achieved through selecting a sample, which will include all PEPs, of Coutts customer account closures over the last 24 months, ensuring an appropriate range of characteristics and reasons underpinning the recommended account closure.

The selected cases will be reviewed by Travers Smith in line with the Phase 1 approach, as follows:

a) Identify the Coutts policies and processes in relation to account closures and review how these were applied in each case;

b) Review how each case was identified for closures, and the escalation process;

c) Review the decisions made, approval thereof, and adequacy of documentation prepared to inform or record the decision (including minutes at various fora), and,

d) Review the closures process, including the appropriateness of the communication of that decision to the client, the time provided to respond, and the account closure itself.

It was anticipated that Travers Smith would complete Phase 1 and report within 4-6 weeks and complete Phase 2 and report by the end of October 2023.