When the UK introduced civil monetary penalties for financial sanctions breaches in 2017, penalties were rare and investigations stretched across years. The dominant compliance question was whether the Office of Financial Sanctions Implementation (OFSI) would act at all. That question has been answered. OFSI now resolves cases through negotiation, and on 19 March 2026 it concluded its first settlement. Yet the most revealing feature of that case is not the penalty imposed. It

When the European Union created the Anti-Money Laundering Authority (AMLA) in mid-2024, the ambition was framed in institutional terms: a single supervisor to end two decades of fragmented, directive-led enforcement. Yet the most consequential development of 2026 is not about who AMLA will supervise. It is about how risk itself must now be measured, evidenced and defended across the entire Union. The reforms unveiled this spring do not adjust the procedural furniture of compl

When the Financial Conduct Authority (FCA) fined Nationwide Building Society £44m on 12 December 2025 for anti-financial crime systems and controls failings between October 2016 and July 2021, it read like a familiar story of weak technology and incomplete due diligence. The regulator described ineffective systems for keeping customer risk assessments current and for monitoring transactions, failings serious enough that the society missed a customer using personal accounts to

When the Bank of Lithuania granted Revolut a European banking licence in 2018, the decision was read as a vote of confidence in a new kind of institution: fast, digital and unburdened by the legacy systems that slow incumbents down. Eight years later, Revolut now serves more than 75 million customers and lifted pre-tax profit by 57 per cent to £1.7bn on revenue of £4.5bn last year, and is sounding out investors on a share sale that values it at $115bn, a figure that, the Fina

When a sanctions screening platform is configured to test every name against well over a thousand watchlists, it is rarely described as a failure of compliance. It is described as thoroughness. The instinct runs deep across the financial system: more lists mean more coverage, more coverage means less risk, and less risk means a defensible position. Yet on 11 June 2026 the Court of Justice of the European Union exposed the flaw in that instinct, and it did so through the small

The phrase ‘voluntary self-disclosure’ (VSD) carries a reassuring implication: that a firm has chosen, freely and without compulsion, to report its own misconduct. The term suggests agency and integrity. Regulators in the US and the UK have built entire enforcement frameworks around this concept, offering penalty reductions, declinations and reputational credit to firms that come forward before they are found out. Yet across sanctions, export controls and anti-bribery enforce

When TD Bank pleaded guilty in October 2024 to violations of the Bank Secrecy Act (BSA) and agreed to pay approximately US 3.09 billion in penalties to the United States Department of Justice and federal regulators, much of the post-mortem focused on culture. Commentators dwelt on the internal "flat cost paradigm" that capped the bank's anti-money laundering (AML) budget regardless of business growth, and on the conduct of individual employees. Less attention was paid to a qu

On 10 February 2025, President Trump signed Executive Order 14209, directing the US Department of Justice (DOJ) to pause enforcement of the Foreign Corrupt Practices Act (FCPA) for 180 days. The stated rationale was that the FCPA had been ‘stretched beyond proper bounds’ in ways that harmed American economic competitiveness. Within weeks, on 20 March 2025, the UK’s Serious Fraud Office (SFO), France’s Parquet National Financier (PNF) and the Office of the Attorney General of

On 9 February 2026, the Office of Financial Sanctions Implementation (OFSI) published revised Enforcement and Monetary Penalties guidance. The reforms introduced a structured case assessment matrix, a settlement scheme, an Early Account Scheme for cooperative subjects and fixed penalties for reporting and licensing offences. OFSI has signalled its intention to seek legislation doubling the maximum civil penalty to the greater of £2 million or 100 per cent of the value of the

In January 2026, the Office of Financial Sanctions Implementation (OFSI) published a penalty notice imposing a £160,000 monetary penalty on Bank of Scotland plc for breaches of the Russia (Sanctions) (EU Exit) Regulations 2019. The facts were unremarkable by the standards of sanctions enforcement. A designated Russian individual, subject to UK sanctions since 2017, opened a personal current account using a UK passport. The name on the passport differed from the OFSI Consolida

For over two decades, the financial services industry has invested heavily in the architecture of compliance. Transaction monitoring systems, sanctions screening engines, customer risk models and suspicious activity reporting workflows have been built, tested, upgraded and rebuilt. Regulatory expectations have sharpened. Enforcement penalties have escalated. In 2025 alone, anti-money laundering (AML) related fines exceeded $1.1 billion in the US, with crypto exchanges, money

On 11 March 2026, the Prudential Regulation Authority (PRA) lifted the restrictions on Revolut's UK banking licence, granting Revolut Bank UK Ltd full authorisation to operate as a bank in its home market. The announcement ended an application process that had begun in January 2021 and had, over the intervening five years, become a case study in the regulatory difficulty of licensing a global-scale neobank. Yet the granting of the licence does not draw a line under Revolut's