Barclays UK FCA Fine: The WealthTek Client Money Account
FCA final notice on Barclays Bank UK explained: how a client money account was opened without checking the Financial Services Register, and the lessons.
On 14 July 2025 the Financial Conduct Authority (FCA) fined Barclays Bank UK PLC 3,093,600 pounds because it opened a client money account for an investment firm called WealthTek without checking whether the firm was allowed to hold client money. It took a single lookup on the FCA's own Financial Services Register to see that it was not. The case is short, specific and instructive for anyone who opens accounts for regulated firms. It was announced alongside a much larger fine on a different Barclays entity, which we cover in our guide to the Barclays final notice on Stunt & Co.
The headline facts
According to the FCA's final notice, the relevant period ran from 1 January 2021 to 4 April 2023. The FCA found that Barclays Bank UK PLC breached Principle 3, which requires a firm to take reasonable care to organise and control its affairs responsibly and effectively with adequate risk management systems, and SYSC 6.1.1R, which requires adequate policies and procedures to counter the risk of financial crime. The notice cites the Money Laundering Regulations 2017 and industry guidance as the underlying customer due diligence standards, but as we read it, it does not find a separate breach of the Regulations. The penalty of 3,093,600 pounds reflects a 30 per cent settlement discount, and the FCA said it also had regard to a voluntary payment of about 6.3 million pounds that Barclays agreed to make to WealthTek's clients.
What WealthTek was allowed to do
WealthTek's permission from the FCA carried a requirement that it could control but not hold client money. That restriction was visible on the Financial Services Register. WealthTek had held an ordinary business account with Barclays since 2010, and the FCA made no findings about that account. The issue was the new account opened in 2021.
How the account was opened
The notice says that in January 2021 a relationship director took a call in which WealthTek was described as a fund manager that received and distributed client funds and needed a client premium account. The records show two changes made so the account could be opened: the firm's industry code was changed from accounting services to fund managers, and its business type code was changed from non-financial LLP to financial LLP so the two matched. The account was then opened. The notice says no further due diligence was done on the source of funds, the clients whose money would be held, or the expected size and nature of transactions, and the Financial Services Register was not checked.
What Barclays' process missed
The FCA's findings describe a process that did not ask the right questions at the point that mattered:
- January to September 2021. There was no requirement to gather information on the purpose of the account, the types of client or activity levels, and no requirement to check the Register. The only check was whether the industry code was on an eligibility list.
- September 2021 to May 2022. A new anti-money laundering questionnaire was introduced, but it did not yet require a Register check or information on expected transaction size.
- From 16 May 2022. A Register check was added to the process.
The account stayed open until April 2023, and the notice records that Barclays decided to close it on 25 April 2023 after a questionnaire sent to WealthTek in July 2022 drew only partial responses. The FCA also noted that Barclays had identified weaknesses in its account-opening procedures in 2020 and reported them to the FCA.
The scale
About 34 million pounds was paid into the account during the relevant period. The FCA used that total, rather than the firm's revenue, as the measure of the harm and rated the seriousness at level 4 on its scale, citing significant loss or risk of loss to consumers, serious weaknesses and the risk that financial crime would be facilitated. It said the failings could have affected a wider number of client money accounts. The notice does not make a finding that WealthTek committed fraud. Separately, the FCA's press release says it charged WealthTek's principal partner in December 2024 and that his trial is scheduled for September 2027. Those charges are allegations, not findings.
Remediation and the voluntary payment
Barclays began a project in 2020 covering 15,454 client money accounts. Customers that failed review were told their accounts would close, and the project finished in October 2023. The bank moved to an eligibility check, a full anti-money laundering questionnaire, a risk assessment and an annual refresh of due diligence. It also agreed to make an ex-gratia payment of 6,281,757 pounds, to be distributed to WealthTek's clients under the administrators' distribution plan. The FCA gave credit for the payment and for Barclays' cooperation, and counted Barclays' earlier fines against it.
Lessons for anyone opening accounts for regulated firms
- Check the regulator's register. If a customer says it is authorised to do something, confirm the permission and any restrictions with the regulator.
- Do not change a classification to make the process fit. Editing a code to match a request defeats the point of the control.
- Ask where the money comes from and whose it is. A client money account needs a clear answer on source, client types and expected volumes.
- Fix known weaknesses quickly. The bank had flagged its own gaps in 2020, and the notice treats the delay in closing them as part of the problem.
- Review existing accounts after you improve the process. New checks for new accounts leave old ones untested.
The same themes appear in our guide to the CB Payments final notice. For structured training on these controls, take a look at our CPD courses.
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 does not describe how any misappropriation happened or list red flags, and it says little about ongoing monitoring of the account, so we do not cover those. The notice also contains small inconsistencies in dates and rounding, so check figures against it before you quote them.
Frequently asked questions
How much was Barclays Bank UK PLC fined?
3,093,600 pounds, after a 30 per cent settlement discount.
What did Barclays fail to check?
The notice says it did not check the Financial Services Register, which showed that WealthTek could control but not hold client money, and did not gather enough information on the source of funds and expected activity.
What did Barclays pay to WealthTek's clients?
A voluntary ex-gratia payment of about 6.3 million pounds, to be distributed under the administrators' distribution plan.
Did the FCA find that WealthTek committed fraud?
No. The notice does not make that finding. The FCA has separately charged WealthTek's principal partner, and those charges are allegations.
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