Governance & SM&CR

Inside the Top 10 FCA Fines: Governance Failures That Cost Firms £2.2 Billion

The ten largest FCA fines since 2013 total about £2.2 billion, led by FX trading and anti-money laundering failures at major banks.

Michaela Clarke

Michaela Clarke

Operations & Compliance Coordinator

19 June 20252 min read
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The ten largest fines imposed by the FCA since it was created in 2013 total about £2.2 billion. Seven arise from market conduct failures in the 2014 and 2015 foreign exchange (FX) and benchmark cases. The other three are financial crime cases.

RankYearFirmAmount (£m)Breach
12015Barclays284.4FX trading controls
22021NatWest264.8Anti-money laundering (criminal prosecution)
32014UBS233.8FX trading controls
42015Deutsche Bank226.8LIBOR and EURIBOR manipulation
52014Citibank225.6FX trading controls
62014JPMorgan Chase222.2FX trading controls
72014RBS217.0FX trading controls
82014HSBC216.4FX trading controls
92017Deutsche Bank163.1Anti-money laundering controls
102021Credit Suisse147.2Financial crime due diligence

Amounts are rounded to £0.1 million. NatWest's £264.8 million was imposed by the court after the FCA's first criminal prosecution under the Money Laundering Regulations; the others are FCA penalties set out in final notices.

What the list shows

In the FX and benchmark cases, the FCA found that firms did not control their trading desks well enough to stop traders sharing confidential client information and trying to manipulate rates. In the financial crime cases, it found weaknesses in customer due diligence and transaction monitoring that left the firms exposed to money laundering risk.

The common thread is governance: in each case the FCA found that the controls the board relied on were not working in practice, and that senior management did not have the information to see it.

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