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
Operations & Compliance Coordinator
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.
| Rank | Year | Firm | Amount (£m) | Breach |
|---|---|---|---|---|
| 1 | 2015 | Barclays | 284.4 | FX trading controls |
| 2 | 2021 | NatWest | 264.8 | Anti-money laundering (criminal prosecution) |
| 3 | 2014 | UBS | 233.8 | FX trading controls |
| 4 | 2015 | Deutsche Bank | 226.8 | LIBOR and EURIBOR manipulation |
| 5 | 2014 | Citibank | 225.6 | FX trading controls |
| 6 | 2014 | JPMorgan Chase | 222.2 | FX trading controls |
| 7 | 2014 | RBS | 217.0 | FX trading controls |
| 8 | 2014 | HSBC | 216.4 | FX trading controls |
| 9 | 2017 | Deutsche Bank | 163.1 | Anti-money laundering controls |
| 10 | 2021 | Credit Suisse | 147.2 | Financial 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.
Need expert regulatory guidance?
Our ex-regulator team helps firms work through complex requirements and evidence compliance with confidence.