Financial services regulatory

FCA enforcement trends in 2025 and implications for 2026

2025 was part of a trend for increased enforcement action since 2020 in enforcement trends based on published fines.

Twenty-two final notices were issued in 2025, comparable with 2024 (27) and 2022 (26), with other years since 2020 having roughly a dozen or so final notices.

The single largest market or sectoral cohort was banking, with seven notices issued against one or more banks, building societies and/or their employees. Conversely, general insurance market intermediaries or risk carriers did not feature at all. In a way, this is not surprising, as the general insurance sector has been subject to about one final notice per year on average since 2020. With the FCA considering the general insurance market more closely in 2026, it is possible that there will be a greater insurance presence in future years’ enforcement.

Highlights: Key trends

The regulatory regime or theme which was most common among the 2025 fines was anti-money laundering (AML)/anti-financial crime (AFC) failings, with five notices in this regard. There was a notable overlap between fines as to banking and AML/AFC.

Barclays Bank PLC was the subject of two fines in July 2025 for:

• One for some £3m in relation to a client account handled for WealthTek 2021–2023, but where Barclays “failed to check the Financial Services Register to confirm whether WealthTek was permitted by the Authority to hold client money”; WealthTek is now subject to fraud and money laundering proceedings.
• Another for some £39m in respect of onboarding and ongoing customer due diligence (CDD) as to Stunt & Co’s Barclays account from Fowler Oldfield between July 2015 and August 2016 (in December 2021, National Westminster Bank Plc was fined £264.8m in respect of Fowler Oldfield’s use of an account to facilitate money laundering, and from which account Fowler Oldfield transferred funds to Stunt & Co).

Nationwide Building Society was fined £44m for wide-scale failings in maintaining up-to-date CDD.

Further cohorts in the general area of financial crime were market abuse (see the Upper Tribunal Decision and related notices as to Lopez Gonzalez, Sheth and Urra) and breaches of the Listing Rules (see the UT decision and related notices as to Donaldson and Arden).

AML/AFC systems and controls failings are a regular feature of enforcement year-on-year, and, bearing in mind the priority at a governmental level for AML (see Anti-money laundering and counter-terrorist financing: Supervision Report: 2023-24) it would not be surprising to see this trend continue, and even grow. 

Highlights: Outliers

Other notable features of 2025 enforcement include the FCA’s interest in personal data, and its unauthorised use, as a component in financial scams – for example, the convictions and fines for Coleman and Harper for having facilitated ‘boiler room’ activity. Given 2025’s increase in reported scams generally (including impersonations of the FCA), this is likely to be a key feature of enforcement activity in 2026.

Finally, 2025 produced a single enforcement action in relation to the late Jeffrey, with James Edward (‘Jes’) Staley being fined for failure to deal openly, cooperatively and with integrity with the FCA when addressing questions as to his interactions with Mr Epstein. It is possible that the release of the ‘Epstein files’ may lead to further challenges on historic disclosures on the part of individuals and institutions in the financial services sector.

Financial crime regulatory issues in 2025 and their implications for 2026

The key financial crime regulatory issues of 2025 and their likely implications for the upcoming year are as follows:

Enforcement intensifies and regulatory strategy shifts (FCA)

In 2025, the FCA continued to take high-impact enforcement actions for financial crime control failures, particularly in anti-money laundering (‘AML’) and sanctions compliance. Notable fines included Nationwide (£44m) for deficient AML systems and Barclays (£42m) for failures in handling clients linked to money-laundering risks. In addition, Monzo was fined £21m for onboarding high-risk customers without adequate controls. These cases illustrate the sustained regulatory focus on robust financial crime systems and controls, demonstrating that significant penalties remain a central part of deterrence strategy.

AML/CTF supervision reform: Structural overhaul

In 2025, the UK government advanced a major reform of the AML supervisory framework. Historically, AML oversight was fragmented across 22 professional body supervisors with varying enforcement capacity. The government consulted on and committed to consolidating supervision – particularly for legal, accounting, and trust-service sectors – under the FCA as the single accountable supervisor. This overhaul aims to improve consistency, enforcement efficacy, and alignment with international standards (especially in anticipation of forthcoming FATF evaluations).

New corporate offence: Failure to prevent fraud

From September 2025, a new corporate criminal offence of ‘failure to prevent fraud’ under the Economic Crime and Corporate Transparency Act 2023 came into force. It holds companies strictly liable for frauds committed by persons working on their behalf unless they can show reasonable preventive procedures. This is likely to lead to increased legal accountability placed on firms’ boards and compliance frameworks.

Economic Crime Plan 2 and system-wide responses

The government’s Economic Crime Plan 2 continues to drive action across public-private partnerships and law enforcement. System-wide disruptions to illicit finance and fraud rose markedly, with thousands of disruptions and increasing asset recoveries, while millions of fraud offences were recorded by national surveys, underscoring scale and persistence of threats. Suspicious Activity Reports (‘SARs’) contributed significantly to asset denial outcomes.

Sanctions and emerging risk domains

The Office of Financial Sanctions Implementation (‘OFSI’) continues refining sanctions enforcement, including updated general licences and an emphasis on proportionate but firm civil penalties for breaches. Meanwhile, preparatory work on expanding regulatory oversight of crypto and digital assets, including plans to bring firms under comprehensive FCA regulation by 2027, progressed through consultations and proposals in 2025.

What this means for 2026

Regulatory consolidation and enforcement will accelerate in 2026:

• Firms in professional services must prepare for FCA supervision with stronger AML processes and risk-based controls.
• The new failure to prevent fraud offence will reshape corporate risk management and elevate board-level accountability.
• Continued sanctions focus will require more dynamic compliance operations, especially for cross-border transactions.
• Fraud detection and disruption, supported by data and technology investments, will remain a key priority, with compliance costs and enforcement risk increasing.

Overall, 2025’s regulatory developments are likely to signal a tougher, more unified UK financial crime regime in 2026, demanding proactive compliance and robust risk governance from regulated entities.