Barclays FCA Fine: £39.3m for Missing the Warning Signs on Stunt & Co

In July 2025 the Financial Conduct Authority (FCA) fined Barclays Bank PLC 39,314,700 pounds for how it handled one commercial customer, a gold refining and trading business called Stunt & Co. Over just over a year the customer received 46.8 million pounds from another company, Fowler Oldfield, which the FCA's press release describes as a money laundering operation. The case is a detailed illustration of three things that go wrong in real banks: thin onboarding, monitoring that does not question unusual activity, and law enforcement information that does not reach the people who could act on it. It sits alongside our other enforcement guides, including the Nationwide final notice and the Monzo FCA fine.

The headline facts

According to the FCA's final notice, dated 14 July 2025, the relevant period ran from 9 January 2015 to 23 April 2021. The penalty of 39,314,700 pounds reflects a 30 per cent discount for early settlement; before the discount it was 56,163,900 pounds. The FCA found that Barclays breached Principle 2, which requires a firm to act with due skill, care and diligence, in how it identified, assessed, monitored and managed the money laundering risk of this customer. Barclays also received a separate fine of about 3.1 million pounds on the same day relating to a different customer, which we cover in a separate guide.

Onboarding: the picture did not add up

The notice says the account application was dated 9 January 2015 and the account opened a week later. The business described itself as gold refining and trading, funded by 1.5 million pounds from its owner's accounts. Several parts of the file pointed in different directions. The anticipated turnover was 500,000 pounds, manually amended to 3 million pounds, and a revenue forecast a month later showed about 11.1 million pounds. The application said the business would not trade outside the European Union, but the business plan described gold sourced from West Africa and high-net-worth customers in the Middle East. The business was given an industry code the notice says was inaccurate, was rated low risk with no recorded rationale, and enhanced due diligence was not applied despite red flags on the attestation form. A second account in euros opened shortly afterwards, which the FCA says signalled a geographic change that should have prompted a fresh look at the risk.

Monitoring: payments outside expected activity

The FCA found that Barclays' understanding of the business was gold from West Africa sold to Middle East buyers. In reality, from July 2015 to August 2016 the customer received 561 electronic payments totalling 46.8 million pounds from Fowler Oldfield, which was not a Barclays customer. The notice says about 8.93 million pounds arrived in 105 payments in roughly eleven weeks, and 200 round-sum payments totalling about 20 million pounds had arrived by the end of January 2016. Overall, 361 of the payments were for exactly 100,000 pounds. On 31 December 2015 a payment of one million pounds, ten times the previous largest from the same source, did not trigger an alert. In October 2015 the customer told the bank it had a joint venture with Fowler Oldfield, but the risk rating was not reconsidered.

Law enforcement information that went nowhere

In August 2016 Barclays' intelligence team received a law enforcement request naming the customer as one of the main recipients of Fowler Oldfield credits. The notice says the team did not finish its analysis, citing resource constraints, and did not share the intelligence with the relationship director or the business unit responsible. Police raids on both companies followed in September 2016. A review of the customer ran from September 2016 and concluded on 1 March 2017 with no further action, without treating the round-sum transfers as red flags. The FCA noted that at the time Barclays had no formal policies for handling law enforcement requests of this kind, and that it formalised procedures afterwards.

Source of wealth that never arrived

The notice records that a 2015 review had found the owner's source of wealth unclear, but that concern was not passed to the relationship director. When source of wealth information was requested in February 2016, it arrived six months late, in August 2016, without supporting evidence. A customer file refresh begun in January 2016 was signed off in January 2017, and the customer remained low risk. Production orders arrived between 2016 and 2020, and a restraint order in August 2018 led to the accounts being frozen. Barclays served notice to close in March 2020 and the accounts were closed in 2020. The notice records that the owner was charged in May 2020 and acquitted in March 2025.

How the FCA weighed it

The FCA treated the 46.8 million pounds as proceeds of crime and said the failings created a significant risk to confidence in the UK market. On the other side, Barclays self-reported in June 2021 and cooperated fully, and it continues a remediation programme that has produced structural changes, including a restructured team for law enforcement requests.

Lessons for banks and professional firms

1. Reconcile the file before you accept it. Inconsistent turnover figures and business descriptions need an explanation, not a manual amendment.
2. Record why a customer is low risk. A rating with no rationale cannot be defended later.
3. Monitor against the story you were told. Large inflows from a source unrelated to the stated business are a trigger to reassess.
4. Treat round-sum patterns as a red flag. Repeated payments of exactly the same amount deserve a question.
5. Get law enforcement information to decision-makers quickly. Resourcing and escalation routes must be planned in advance.
6. Chase source of wealth evidence. A late, unsupported answer is not an answer.

Our guide to suspicious activity reporting explains how internal reporting should work, and our CPD courses offer structured training on these controls.

What we could not confirm

We worked from the FCA's press release and final notice of July 2025, read through a summarising tool. The notice was cut off partway through its section on failings, and its penalty calculation and list of aggravating and mitigating factors were not available to us, so this guide does not cover them. Check figures and paragraph references against the notice before you quote them.

Frequently asked questions

How much was Barclays Bank PLC fined?

39,314,700 pounds, after a 30 per cent discount for early settlement.

Which rule did the FCA say was breached?

Principle 2, due skill, care and diligence, in how the money laundering risk of this customer was managed.

Who was Fowler Oldfield?

According to the FCA's press release, a money laundering operation that sent 46.8 million pounds to the customer in just over a year. It was not a Barclays customer.

What happened to the customer's owner?

The notice records that he was charged in May 2020 and acquitted on 4 March 2025.