This enforcement action highlights the urgent need for financial institutions to reinforce AML
frameworks, conduct robust client due diligence, and escalate suspicious indicators proactively.
1. Penalty Breakdown
Client Association Fine Amount (GBP) Reason for Penalty
Stunt & Co £39,300,000 AML failures; ignored money laundering indicators
WealthTek LLP £3,100,000 Poor onboarding; failed regulatory status check
Total FCA Penalty £42,400,000 Systemic financial crime control breaches
Voluntary Payment £6,300,000 Compensation paid to impacted WealthTek clients
2. Client Transactions & Exposure
Entity Involved Amount Transacted
(GBP) Issue Identified
Fowler Oldfield → Stunt &
Co £46,800,000 Funds linked to known laundering
operation
Deposits to WealthTek
Account £34,000,000 Barclays did not verify FCA
authorization
3. Compliance Lapses
Failure Point Implication
No verification of WealthTek’s FCA status Unauthorized client account setup
Continued banking for flagged entities Ignored red flags post law enforcement action
Delayed internal reviews Reactive measures post peer enforcement cases
Lack of risk escalation systems Ineffective monitoring and alert handling
4. Regulatory Response & Remediation
• FCA highlighted systemic breakdown in AML governance
• Barclays initiated a major AML framework overhaul
• Improvements include stronger client onboarding, transaction monitoring, and centralized risk
escalation workflows
Key Takeaways for AML/KYC Professionals
DISCLAIMER: This report is based on publicly available information. RELIX AML-KYC ACADEMY is not liable for any inconsistencies, updates, or differing interpretations. The content is for
informational purposes only.
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• Mandatory credential verification before onboarding
• AML systems must flag and escalate risks promptly
• Voluntary compensation doesn’t substitute strong compliance
• Ongoing training and tech investment are critical for integrity