Barclays Financial Crime Policy
Barclays' Financial Crime Policy Position Statement sets out the bank's commitment to preventing financial crime across four risk areas:
Anti-Bribery & Corruption
Preventing bribery in all forms across all operations
AML & Counter-Terrorist Financing
Detecting and preventing money laundering and terrorism funding
Anti-Tax Evasion Facilitation
Ensuring the bank does not facilitate tax evasion
Sanctions
Compliance with all applicable sanctions regimes
The policy is supported by eleven group-wide Financial Crime Standards and applies to all employees, businesses, and legal entities within the Barclays Group. Barclays aligns with FATF recommendations, Wolfsberg Principles, and UK Finance standards, with a dedicated global Financial Crime function sitting within Compliance.
The 2025 Elevation to Principal Risk
In a significant move, Barclays elevated financial crime risk to a principal risk within the Enterprise Risk Management Framework (ERMF), effective 1 January 2025. Previously managed as a component of compliance risk, financial crime now sits alongside credit risk, market risk, and operational risk as one of ten principal risks.
Elevation to principal risk means financial crime now receives Board-level oversight, dedicated risk appetite metrics, and standalone reporting. It signals that the Board considers financial crime a standalone, material threat to the bank — not simply a compliance matter.
The Stunt & Co Case: GBP 39.3 Million Fine
FCA Enforcement: Barclays Bank PLC
In 2025, the FCA fined Barclays Bank PLC GBP 39.3 million (part of a combined GBP 42 million penalty) for failing to properly manage financial crime risks connected to politically exposed persons and high-risk clients.
Key findings from the FCA Final Notice:
- Barclays onboarded Stunt & Co without gathering sufficient information about the nature of the business or its expected transaction patterns.
- Stunt & Co received GBP 46.8 million from Fowler Oldfield (later convicted of money laundering) in just over one year.
- Despite law enforcement providing information and police raiding Fowler Oldfield's premises, Barclays did not conduct a proper review for five years.
- Barclays breached FCA Principle 2 (conducting business with due skill, care and diligence) and Principle 3 (organising affairs responsibly with adequate risk management).
“The consequences of poor financial crime controls are very real — they allow criminals to launder proceeds of their crimes.”
— Therese Chambers, FCA Joint Executive Director of Enforcement and Market Oversight (FCA Press Release)
The WealthTek Case: GBP 3.1 Million Fine
FCA Enforcement: Barclays Bank UK PLC
In a separate but concurrent action, the FCA fined Barclays Bank UK PLC GBP 3.1 million for failures related to the WealthTek relationship:
- Barclays opened a client money account for WealthTek without verifying its regulatory status — a check of the FCA's Financial Services Register would have revealed WealthTek lacked the necessary permissions.
- GBP 34 million was deposited into the account.
- After updating its procedures, Barclays took 11 months to close the account.
- Barclays made a voluntary ex-gratia payment of GBP 6,281,757 to affected clients.
A simple check of the FCA Register would have prevented GBP 34 million from flowing through an unauthorised firm's account. Basic due diligence saves millions.
The Full Cost of Failure
| Impact | Detail |
|---|---|
| Direct financial penalty | GBP 42.3 million in FCA fines (FCA) |
| Voluntary compensation | GBP 6.28 million ex-gratia to WealthTek clients (FCA Final Notice) |
| Reputational damage | International media coverage, investor concern, damage to client trust |
| Regulatory scrutiny | Heightened FCA oversight, potential restrictions on new business |
| Operational cost | Remediation programmes, enhanced monitoring, additional compliance staffing |
| Personal liability | Senior managers face individual scrutiny under the Senior Managers & Certification Regime |
The FCA's 2026 priorities make clear that financial crime enforcement will intensify further, with intelligence-led supervision and material AML deficiencies treated as governance failings.
Every employee — regardless of role — has a personal responsibility to understand AML obligations, recognise red flags, and report suspicions. The Stunt & Co and WealthTek cases demonstrate that failures are not abstract: they result in real penalties, regulatory action, and reputational damage.
Knowledge Check
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