What this page is for

This is not a list of random enforcement headlines. It is an evidence page.

The purpose is to show a repeated regulatory pattern: firms are sanctioned when they cannot demonstrate that their systems, controls and monitoring are operating effectively. In many of these cases, the practical issue is not a single broken tool. It is incomplete visibility, weak end-to-end ownership, late detection, insufficient monitoring coverage, or an inability to prove that critical data and controls are working as intended.

Selected regulator-backed cases

FCA United Kingdom 2024

Metro Bank — £16.7m

The FCA fined Metro Bank £16,675,200. The regulator said that between June 2016 and December 2020, Metro failed to have the right systems and controls to adequately monitor over 60 million transactions, with a value of over £51 billion, for money laundering risks.

Why it matters: this is a direct reminder that monitoring effectiveness is not just about the existence of a monitoring process. It is about whether the right population of activity is actually being monitored, with sufficient coverage and control support.

Official FCA source
FCA United Kingdom 2024

Starling Bank — £29m

The FCA fined Starling Bank £28,959,426 for financial crime failings related to its financial sanctions screening. The FCA also said the bank repeatedly breached a requirement not to open accounts for high-risk customers.

Why it matters: screening is often spoken about as if it is only a rules or list-matching challenge. In practice, data completeness, customer classification, and operational control discipline matter just as much.

Official FCA source
FCA United Kingdom 2025

Monzo — £21.1m

The FCA fined Monzo Bank Ltd £21,091,300 for inadequate anti-financial-crime systems and controls between October 2018 and August 2020. The regulator also said Monzo repeatedly breached a requirement preventing it from opening accounts for high-risk customers between August 2020 and June 2022.

Why it matters: rapid growth amplifies control weaknesses. When governance, screening, onboarding and monitoring controls do not keep pace, weaknesses become structural rather than isolated.

Official FCA source
FCA United Kingdom 2025

Nationwide — £44m

The FCA fined Nationwide Building Society £44 million for inadequate anti-financial-crime systems and controls. The regulator said that during the relevant period Nationwide had ineffective systems for keeping up-to-date due diligence and risk assessments for all its personal current account customers and for monitoring their transactions.

Why it matters: this is a useful reminder that financial crime control weakness is not only about monitoring logic. Customer due diligence, risk assessment freshness and monitoring effectiveness sit in the same control chain.

Official FCA source
Federal Reserve United States 2024

Silvergate — $43m

The Federal Reserve fined Silvergate Capital Corporation and Silvergate Bank $43 million for deficiencies in Silvergate's monitoring of transactions in compliance with anti-money laundering laws.

Why it matters: even where the regulatory wording is concise, the signal is strong: monitoring coverage and monitoring effectiveness remain central areas of supervisory focus, especially where transaction volumes and risk complexity are high.

Official Federal Reserve source
Federal Reserve United States 2017

Deutsche Bank — $41m

The Federal Reserve announced a $41 million penalty and consent order against Deutsche Bank AG for anti-money-laundering deficiencies. In the accompanying order, the Fed said deficiencies in Deutsche Bank's transaction monitoring capabilities prevented it from properly assessing BSA/AML risk for billions of dollars in potentially suspicious transactions processed between 2011 and 2015 for certain affiliates.

Why it matters: this is a powerful example of how transaction monitoring weakness is not merely a model issue. Coverage, data quality, affiliate data sufficiency and the overall capability to assess risk are tightly connected.

Official Federal Reserve source
FinCEN / OCC United States 2024

TD Bank — $1.3bn

FinCEN announced a $1.3 billion settlement with TD Bank and described it as the largest penalty against a depository institution in U.S. Treasury and FinCEN history. In the FinCEN consent order, the agency said TD Bank's monitoring system lacked transaction codes necessary to monitor 98% of domestic ACH transactions. Separately, the OCC announced a cease and desist order and a $450 million civil money penalty for deficiencies in the bank's BSA/AML compliance program.

Why it matters: this is the clearest modern example of why monitoring architecture, transaction coding, coverage design and investment discipline matter. A monitoring estate that does not actually see what it needs to see is not a strong control environment.

Official FinCEN source
Official OCC source

What this pattern is really telling us

Regulators use different language. One case may focus on transaction monitoring. Another may focus on sanctions screening. Another may emphasise customer due diligence, high-risk account restrictions, or AML programme deficiencies.

But the pattern is consistent. Firms get into serious trouble when they cannot show that critical controls are supported by complete visibility, reliable data flows, effective screening or monitoring coverage, timely escalation and sufficiently strong systems and controls around the full chain.

This is exactly why end-to-end data integrity matters. The issue is not whether a dashboard exists. It is whether the data feeding the control environment is complete, correct, and properly governed from source through to decision.

What this means in practice

1

Treat control coverage as an evidence problem

Do not assume monitoring is effective because alerts continue to fire. Ask whether the right population is actually being seen.

2

Separate completeness from correctness

Missing data and distorted data create different failure modes. Both can lead to regulatory exposure if not explicitly controlled.

3

Challenge visible stability

Stable dashboards, reports and alert volumes do not prove data integrity. They may only prove that the system is functioning on whatever arrived.

4

Connect data issues to governance

Most enforcement outcomes are not just “technical”. They expose weak ownership, insufficient escalation and control environments that did not mature fast enough.

How to read this page properly

It would be too simplistic to say that every one of these fines was caused by data quality alone. That is not the point.

The point is that failures in monitoring, screening and broader financial crime controls repeatedly intersect with the same structural weaknesses: incomplete visibility, poor coverage, inadequate systems, weak governance, control environments that do not scale, and gaps between what firms assume is working and what they can actually prove.