In two separate cases published on 14 July 2025, Barclays Bank UK PLC and Barclays Bank PLC were fined a total of £42 million for separate instances of failings in their financial crime risk management – relating to Barclays' customers WealthTek and Stunt & Co.
WealthTek
The FCA issued a Final Notice to Barclays Bank UK PLC, imposing a penalty of £3,093,600 for systemic failings in its anti-money laundering (AML) controls and client due diligence (CDD) processes. The failings related specifically to the opening and management of client money accounts for WealthTek LLP. In addition to the penalty, Barclays agreed to make a voluntary ex-gratia payment of £6,281,757 to WealthTek’s clients.
WealthTek was an FCA authorised firm which in April 2023 was subject to urgent supervisory intervention by the FCA and the appointment of special administrators. In December 2024, John Dance, the former WealthTek principal partner, was charged with the alleged misappropriation of £64 million of customer funds between 2014 and 2023.
In 2021 Barclays opened a client account for WealthTek, which it subsequently operated, allowing a total of over £34 million to be deposited. In opening the client account, Barclays failed to check the FCA register for the firm; had it done so, it would have seen that WealthTek had imposed a requirement on its Part 4A authorisation preventing WealthTek from holding (as opposed to controlling) client money.
During 2022 Barclays improved its procedures to ensure that the AML questionnaire for regulated customers includes a question on whether permission was held to hold client funds, which is manually checked against the register. Between August 2022 and March 2023 Barclays unsuccessfully sought to update the AML it held on WealthTek, ultimately leading Barclays to take the decision to close the account on 25 April 2023.
Comment
The most striking feature of this case is its remarkable similarity to the Premier FX matter some three years ago, which we wrote about in a previous edition of Enforcement Watch.
Both cases involve regulatory failure, enforcement by the FCA against Barclays (as banker to the firm) coupled with an ex-gratia payment to clients. In this case Barclays might feel particularly aggrieved - the press has widely reported that a whistle-blower raised concerns about WealthTek to the FCA two years prior to the firm collapsing.
In AML cases, the FCA will cite its long history of taking action in similar cases and treat this as an aggravating factor meriting an increase to penalty. In the present case the FCA balanced this against Barclays ex-gratia payment and cooperation in the investigation. In this regard the FCA reports that the investigation into Barclays was opened in April 2025 and concluded within three months. Barclays' extensive cooperation contributed to this expedited outcome. The FCA determined that overall Barclays was entitled to a 15% reduction in penalty by way of mitigation.
Stunt & Co
The FCA issued a final notice imposing a financial penalty of £39,314,700 for failing to adequately manage money laundering risks associated with providing banking services to Stunt & Co. The FCA found that Barclays did not gather enough information at the start of the relationship or carry out proper ongoing monitoring. In the space of just over a year, Stunt & Co received £46.8 million from Fowler Oldfield, in what the FCA described as a multimillion-pound money laundering operation.
Barclays only conducted a review of its exposure to Fowler Oldfield through its customers, including Stunt & Co, after it learned of the FCA’s decision to prosecute NatWest over their relationship with Fowler Oldfield.
Barclays failed to respond appropriately to several trigger events, including court orders, police raids, and the charging of Stunt & Co’s director, James Stunt, with money laundering offences (from which he was later acquitted).
Comment
When one reads the factual narrative in the Final Notice it seems surprising that Barclays would fail to pick up on so many red flags, including:
- significant funds received by Stunt & Co from Fowler Oldfield from July 2015 that were inconsistent with Barclays’ understanding of Stunt & Co’s business and significantly in excess of the turnover Stunt & Co had informed Barclays was likely at account opening;
- a request from law enforcement in 2016 indicating that Fowler Oldfield may have been used to launder the proceeds of suspected money laundering and that Stunt & Co was one of the main recipients of electronic credits from Fowler Oldfield;
- adverse media in September 2016 that the premises of both Stunt & Co and Fowler Oldfield had been raided by the police, which (despite being considered by Barclays) did not raise the account risk rating; and
- the fact of Mr Stunt being charged with money laundering offences in May 2020 (although recently acquitted) did not prompt any consideration of whether Barclays should review the account activity of Stunt & Co until 2021.
An issue with many large firms can be that because responsibility for different aspects of financial crime are dispersed amongst different departments (relationship management, transaction monitoring, law enforcement liaison) so no one individual looks holistically at the client relationship and full information about the customer is dispersed within the Bank. Banks need to ensure that ongoing monitoring takes place with the benefit of all relevant information and red-flags trigger adjustments to the risk rating of the customer and manual reviews.
As with the WealthTek case, the penalty imposed by the FCA was calculated as a percentage of the total sums which were paid into the relevant bank account. Unlike WealthTek, there was little by way of mitigation, and the FCA therefore imposed a 20% uplift on the penalty for aggravating factors, principally its long history of taking action in similar cases which meant that Barclays knew or ought to have known of the importance of adequate AML controls. Given the massive resources that firms like Barclays devote to AML (albeit, as these cases demonstrate, not always effectively) no-one doubts that Barclays does understand that importance.