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Section 3 of 3

Case Studies: Stunt & Co & WealthTek

Two landmark enforcement cases. GBP 42 million in combined fines. The real cost of failing to act on red flags.

Case Study 1: Stunt & Co

FCA Enforcement: Barclays Bank PLC

Stunt & Co was a business customer of Barclays Bank PLC linked to James Stunt, a high-profile figure known for his connection to the Ecclestone family. The account became the subject of one of the FCA's largest enforcement actions of 2025.

GBP 46.8M
from Fowler Oldfield
5 Years
without a proper review
GBP 39.3M
FCA fine

Timeline of Failures

2012
Stunt & Co onboarded. Insufficient information gathered about expected activities.
2012–2013
GBP 46.8 million received from Fowler Oldfield. Round-figure payments, high volume, no commercial rationale.
Police Action
Police raided Fowler Oldfield. The connection to Stunt & Co was clear. Barclays still did not act swiftly.
5 Years Later
Barclays finally conducts a proper review of the Stunt & Co relationship.
2025
FCA fines Barclays Bank PLC GBP 39,344,700. Breached Principle 2 (skill, care, diligence) and Principle 3 (management and control).

“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)
Gavel striking block - regulatory enforcement

Case Study 2: WealthTek

FCA Enforcement: Barclays Bank UK PLC

WealthTek was a discretionary fund management firm that opened a client money account with Barclays Bank UK PLC. What followed was a textbook failure of basic due diligence.

GBP 34M
deposited without checks
11 Months
to close the account
GBP 9.3M+
total financial impact
Key Lesson

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.

Combined Impact: GBP 42 Million

The Oxford Business Law Blog's analysis highlighted that the total GBP 42 million penalty sends a clear message: the FCA will pursue enforcement even against the largest institutions when financial crime controls are inadequate.

GBP 42M
combined FCA fine for both cases

Key Lessons

Continuous Monitoring

Dynamic risk assessment must replace static, point-in-time reviews

Event-Driven Reviews

Law enforcement activity involving a customer's counterparties must prompt immediate review

Basic Checks Matter

The simplest verification — checking a public register — would have prevented the WealthTek incident

Speed of Action

An 11-month delay in closing a known-risk account is indefensible

Escalate Early

Escalation pathways must be clear, tested, and actually followed

Red flags dashboard showing financial monitoring alerts

Knowledge Check

Answer all 5 questions to complete Lesson 4 and unlock Lesson 5.

Question 1 of 5
How much money did Stunt & Co receive from Fowler Oldfield?
Question 2 of 5
What basic check did Barclays fail to perform when opening the WealthTek account?
Question 3 of 5
How long did Barclays take to properly review the Stunt & Co relationship after red flags emerged?
Question 4 of 5
Which FCA Principles did Barclays breach in the Stunt & Co case?
Question 5 of 5
What was the total financial impact of the WealthTek case, including the fine and ex-gratia payment?
questions answered correctly
All questions answered — Lesson 5 unlocked!
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