Enforcement Actions
Weak bank customer due diligence in spotlight again after Barclays fined £42 million
• 0 minute read
July 17, 2025
Barclays was handed two separate fines by the UK Financial Conduct Authority (FCA) yesterday for failures in its financial crime systems and controls. Both fines involved poor customer due diligence around money laundering risks, and come less than a fortnight after Monzo Bank was fined £21 million over customer onboarding failings.
Simran Bharaj, founder of financial crime compliance group GKSB Consultancy, said the Barclays fines emphasise once again that banks are not doing enough on customer due diligence.
Commenting on the fines on July 16, Therese Chambers, joint executive director of enforcement and market oversight at the FCA, said banks “need to take responsibility and act promptly, particularly when obvious risks are brought to their attention”.
The latest fines mean that Barclays has now been fined a total of £115 million over the past decade because of failures in its financial crime systems, controls and oversight.
Stunt & Co
In the first of the two fines, Barclays Bank Plc was fined £39.3 million over breach of Principle 2, that is, failing to adequately identify, assess, monitor and manage the money laundering risks associated with the provision of banking services to gold bullion firm and refinery Stunt & Co Ltd.
“Between July 2015 and August 2016, Stunt & Co received 561 payments from Fowler Oldfield, totalling £46.8 million; 361 of these payments were round payments of £100,000. The authority considers that those monies represented the proceeds of crime and that Stunt & Co’s account was used to launder the funds,” the FCA said in its final notice.
The final notice lists a series of failures to follow up on red flags about Stunt & Coʼs dealings with second-hand gold dealer Fowler Oldfield, including a police raid in 2016.
“It was only after Barclays learned in March 2021 of the authority’s decision to charge NatWest with criminal offences under the 2007 Regulations, in respect of its relationship with Fowler Oldfield, that Barclays commenced a significant investigation in respect of Stunt & Co and certain other customers who had received funds from Fowler Oldfield,” the final notice said.
NatWest was fined £265 million in December 2021, after it was convicted of three offences of failing to comply with money laundering regulations. In all, £365 million went through Fowler Oldfield’s account at NatWest between November 2012 and June 2016.
Fowler Oldfield directors Gregory Frankel and Daniel Rawson were convicted of money laundering in March 2025, and sentenced to 11 years and 10 years, respectively.
Barclays: A decade of financial crime fines
July 2025 – £3.1 million for Principle 3 failure in relation to customer due diligence involving WealthTek
July 2025 – £39.3 million for Principle 2 breach with regard to Stunt & Co Ltd
February 2022 – £783,800 for Principle 2 failings in relation to Premier FX
November 2015 – £72 million for Principle 2 breach after the bank executed a transaction involving politically exposed persons (PEPs)
“In relation to Stunt & Co, the relevance here is the plausibility of the information being assessed against what the customer has told you, what you know of the industry and sector, and what the transactions show you; being proactive on received intelligence (a theme from the Monzo fine); and lastly, the importance of properly risk assessing the customer after onboarding,” Bharaj said.
“Updating the customer risk assessment is key, as is having a skilled financial crime reviewer looking at the risks properly.”
James Stunt, the former son-in-law of Formula One Group founder Bernie Ecclestone, was acquitted of money laundering charges in relation to money received by Stunt & Co from Fowler Oldfield in March 2025.
WealthTek
Wealth management firm, WealthTek was ordered to cease trading by the FCA in April 2023. John Dance, the firm’s principal partner, will stand trial in September at Southwark Crown Court over an alleged misappropriation of £64 million of customer funds.
The final notice against Barclays Bank UK Ltd makes clear that “one simple check” of the Financial Services Register should have alerted the bank to the fact that WealthTek was not permitted to hold client money.
Barclays failed to do this because its policies and procedures did not require such a check until May 2022. According to the final notice, even after the requirement was introduced, the bank took a further 11 months to close WealthTek’s account.
The FCA concluded that Barclays UK breached Principle 3 and SYSC 6.1.1R by failing to organise and control its affairs responsibly and effectively in connection with the opening of the client account. In addition to the 3.1 million fine, Barclays has agreed to make a voluntary ex-gratia payment of £6.3 million to WealthTek customers who lost money.
Bharaj said the FCA fine against Barclays in relation to WealthTek “finally clarifies explicitly the regulator’s position on pooled accounts”, adding that banks have often relied on the regulated status of customers when opening client accounts.
“The [FCA] position is now clear that firms should be taking active steps to understand who their customers are, their business model and in what capacity the pooled accounts are being used, and to do their own checks that they are not dealing with the proceeds of crime,” she said.
Bharaj believes some banks may now review whether they continue to offer client accounts. “I wouldn’t be surprised to see pooled accounts decreasing in the market. They are high risk and expensive to run,” she said.
Commenting after the fines were published, Barclays said: “Barclays remains deeply committed to the fight against financial crime and fraud. The FCA’s investigation relating to Stunt & Co was centred around historical money laundering activity and made no findings that the bank had breached money laundering regulations.
“As acknowledged by the FCA, Barclays undertook an extensive review and self-reported its findings to the FCA. Barclays fully cooperated with both investigations and has further strengthened its financial crime and other control capabilities.”