FCA Fines in 2025: Lessons for Compliance Teams

Introduction: A Year of Significant Enforcement

The Financial Conduct Authority's enforcement activity in 2025 demonstrated the regulator's continued commitment to holding firms and individuals accountable for compliance failures. With total fines reaching £123.9 million (excluding court fines), the FCA sent a clear message about the consequences of inadequate systems and controls, particularly in the area of financial crime prevention.

For compliance professionals, the 2025 enforcement landscape provides invaluable insights into regulatory expectations. This article examines the major enforcement actions, identifies common themes, and distils practical lessons that compliance teams can apply to strengthen their firm's regulatory posture heading into 2026.

2025 Enforcement Statistics at a Glance

Total fines issued: £123,911,524 (excluding court fines)

Largest single fine: Nationwide Building Society - £44.1 million

Key themes:

Financial crime controls dominated enforcement (70%+ of total fines)
Increased focus on individual accountability
Market abuse and manipulation cases targeting investment banking
Transaction reporting failures across multiple firms

Notable trend: The FCA's case closure rate increased significantly, with open investigations dropping from 188 to 130 as the regulator delivered on its strategic goal of conducting fewer investigations but resolving them faster.

Major Fines Summary

| Firm/Individual | Fine Amount | Date | Primary Issue | |-----------------|-------------|------|---------------| | Nationwide Building Society | £44.1m | Dec 2025 | Financial crime controls | | Barclays Bank plc | £39.3m | Jul 2025 | AML failures | | Monzo Bank | £21.1m | Jul 2025 | Financial crime controls | | London Metal Exchange | £9.2m | Mar 2025 | MiFID conduct violations | | Barclays Bank UK plc | £3.1m | Jul 2025 | Client money due diligence | | Mako Financial Markets | £1.7m | Feb 2025 | Financial crime controls | | James Staley (individual) | £1.1m | Jul 2025 | Integrity breaches | | Jean-Noel Alba (individual) | £1.05m | Jul 2025 | False statements to FCA | | Sigma Broking | £1.1m | Jul 2025 | Transaction reporting |

Major Enforcement Actions of 2025

Nationwide Building Society - £44.1 Million (December 2025)

The largest fine of 2025 was imposed on Nationwide Building Society for breaches of Principle 3 and associated SYSC rules regarding financial crime controls. The FCA found that Nationwide maintained inadequate systems for customer due diligence and risk assessments between October 2016 and July 2021, affecting all personal current account customers.

This case exemplifies the FCA's expectation that firms must have robust, risk-based financial crime controls that are regularly reviewed and updated. Nationwide's systems failed to keep pace with the scale and complexity of its customer base.

Key lesson: Financial crime controls must evolve with the business. Systems appropriate for a smaller operation may become inadequate as customer numbers grow.

Barclays Bank - £42.4 Million Combined (July 2025)

Barclays faced two separate enforcement actions totalling £42.4 million:

Barclays Bank plc - £39.3 million: The FCA found that Barclays failed to adequately manage money laundering risks associated with Stunt & Co between 2015 and 2021. The firm received £46.8 million from Fowler Oldfield, which was subsequently identified as part of a multimillion-pound money laundering operation.

Barclays Bank UK plc - £3.1 million: A separate action addressed failures to conduct sufficient due diligence before opening a client money account for WealthTek, which later collapsed causing customer harm.

Key lesson: Correspondent banking and client money account opening procedures require rigorous due diligence. The source of funds must be thoroughly investigated, particularly for high-value relationships.

Monzo Bank - £21.1 Million (July 2025)

The digital challenger bank was fined for conduct failures under Principle 3, relating to financial crime control weaknesses between 2018 and 2020. This case is particularly significant as it demonstrates the FCA's willingness to take action against newer fintech firms, not just traditional institutions.

Key lesson: Rapid growth does not excuse inadequate compliance infrastructure. Firms must ensure their systems and controls scale appropriately with business expansion.

London Metal Exchange - £9.2 Million (March 2025)

The LME was fined for wholesale conduct violations under MiFID RTS 7, marking a significant enforcement action in the wholesale markets space. This case highlighted the FCA's continued focus on market infrastructure providers and their obligations to maintain orderly markets.

Key lesson: Recognised Investment Exchanges face the same expectations for robust systems and controls as other regulated firms.

Individual Accountability: Senior Managers in the Spotlight

A striking feature of 2025 enforcement was the increased focus on individual accountability, with several high-profile cases resulting in prohibitions and substantial personal fines.

James Edward Staley - £1.1 Million + Prohibition (July 2025)

The former Barclays CEO was fined over £1.1 million and prohibited from holding senior management functions. The FCA found integrity breaches and regulatory non-cooperation during its investigation into his relationship with Jeffrey Epstein. This case reinforces that senior managers face personal consequences for misleading the regulator.

Jean-Noel Alba - £1.05 Million + Prohibition (July 2025)

The former H2O deputy CEO was fined and prohibited for providing false and misleading statements to the FCA during an investigation. This case demonstrates the severe consequences of failing to cooperate honestly with regulatory enquiries.

Market Abuse Cases - Multiple Individuals (August 2025)

Three individuals at Mizuho were fined for market manipulation through spoofing:

Diego Urra: £223,400
Jorge Lopez Gonzalez: £100,000
Poojan Sheth: £57,600

These cases show the FCA's continued vigilance in detecting and punishing market abuse, even relatively small-scale manipulation.

Pension Transfer Advice Failures (May 2025)

Two individuals were fined and prohibited for inappropriate pension transfer advice:

Toni Fox: £567,584
David Brian Price: £465,415

These cases highlight the FCA's ongoing scrutiny of the pensions sector, particularly advice around defined benefit transfers.

Common Compliance Failures Identified

Across the breadth of 2025's enforcement actions, several recurring themes emerged.

Inadequate Financial Crime Controls

The dominant theme of 2025 enforcement was weak financial crime frameworks. Specific failings included:

Customer due diligence gaps: Failure to identify ultimate beneficial owners and understand the purpose of business relationships
Transaction monitoring weaknesses: Systems that were not calibrated to detect suspicious patterns or that generated excessive false positives, leading to alert fatigue
Risk assessment failures: Inadequate categorisation of customer risk, leading to high-risk relationships receiving insufficient scrutiny
Resource constraints: Compliance teams that were under-resourced relative to the firm's risk profile and transaction volumes

Transaction Reporting Failures

Multiple firms faced enforcement for transaction reporting deficiencies under MiFIR:

Sigma Broking Limited (£1.1 million): Transaction reporting failures under PRIN 3 and MiFIR
Infinox Capital Limited (£99,200): Transaction reporting failures under MiFIR

These cases emphasise the importance of accurate, complete, and timely regulatory reporting.

Governance and Oversight Deficiencies

Several cases highlighted inadequate senior management oversight:

Boards lacking sufficient understanding of financial crime risks
Inadequate management information reaching senior leadership
Failure to act on known control weaknesses
Insufficient challenge from second and third lines of defence

Individual Integrity Failures

The prohibitions issued in 2025 shared common elements:

Misleading statements to the regulator
Failure to disclose material information
Non-cooperation with investigations
Breach of the fundamental duty of honesty

Lessons for Compliance Teams

The enforcement landscape of 2025 offers several clear lessons for compliance professionals.

1. Financial Crime Controls Require Continuous Investment

The Nationwide, Barclays, and Monzo cases demonstrate that financial crime controls must be:

Proportionate to the firm's size and risk profile
Regularly reviewed and updated
Adequately resourced
Subject to independent testing and assurance

Compliance teams should benchmark their financial crime frameworks against regulatory expectations and peer practice, addressing gaps before they attract supervisory attention.

2. Individual Accountability is Real

The personal fines and prohibitions issued in 2025 should focus senior managers' attention on their personal regulatory obligations. Actions to take include:

Ensure Statements of Responsibilities accurately reflect actual accountability
Maintain clear audit trails of oversight activities
Cooperate fully and honestly with regulatory enquiries
Challenge information received from the business and do not simply accept assurances

3. Transaction Reporting Requires Ongoing Attention

The Sigma Broking and Infinox cases highlight that transaction reporting failures will attract enforcement action. Firms should:

Conduct regular reconciliations and completeness checks
Monitor for reporting errors and systemic issues
Maintain appropriate oversight of delegated reporting arrangements
Respond promptly to regulatory feedback on reporting quality

4. Culture and Tone from the Top Matter

The integrity failures that led to prohibitions underscore the importance of ethical culture. Firms should:

Ensure senior leaders model expected behaviours
Create an environment where concerns can be raised safely
Take swift action when misconduct is identified
Reinforce that regulatory cooperation is non-negotiable

Looking Ahead: Enforcement Priorities for 2026

Based on 2025 enforcement patterns and FCA communications, firms should anticipate continued focus on:

Financial Crime

With over 70% of 2025 fines relating to financial crime failures, this area will remain a priority. The FCA has signalled particular interest in:

APP fraud controls and the new mandatory reimbursement regime
Sanctions compliance in light of ongoing geopolitical developments
Cryptocurrency and digital asset-related financial crime

Consumer Duty Outcomes

Now embedded across the industry, the FCA will expect to see evidence of improved customer outcomes. Firms that cannot demonstrate Consumer Duty is driving real change face enforcement risk.

Operational Resilience

With the March 2025 deadline passed, the FCA will supervise against operational resilience requirements. Firms whose resilience arrangements prove inadequate during stress events can expect regulatory consequences.

Market Integrity

The investment banking market abuse cases signal continued vigilance around trading conduct. Surveillance systems must be capable of detecting manipulation, and firms must act on identified concerns.

How MEMA Can Help

Navigating the complex regulatory environment requires expertise, experience, and a proactive approach. At MEMA Consultants, we work with firms across the financial services sector to strengthen compliance frameworks and reduce regulatory risk.

Our services include:

Regulatory Health Checks: Comprehensive assessments of your compliance arrangements against FCA expectations and enforcement trends
Financial Crime Framework Reviews: Assessment and enhancement of AML, sanctions, and fraud controls
SM&CR Advisory: Support for senior managers in understanding and discharging their regulatory responsibilities
Transaction Reporting Assurance: Review of reporting completeness and accuracy
Enforcement Preparedness: Development of procedures for responding to regulatory enquiries and investigations

The £124 million in fines issued during 2025 underscores the importance of maintaining robust compliance arrangements. By learning from others' experiences and taking proactive steps to address potential vulnerabilities, firms can protect themselves, their customers, and their reputation.

Ready to strengthen your compliance framework? Contact our team to discuss how MEMA Consultants can support your regulatory objectives.

This article is intended for general information purposes only and does not constitute legal or regulatory advice. Firms should seek professional guidance tailored to their specific circumstances.