---
title: FCA compliance has left the back office
description: The FCA issued GBP176 million in fines in 2024 and a further GBP124 million in 2025. Nationwide, Barclays, Monzo, Starling, Citigroup. The pattern is the same across every case - compliance infrastructure that failed to keep pace with the business.
author: Declan Sheehy
datePublished: 2026-01-15
dateModified: 2026-04-28
url: https://www.oneblackwater.com/article-commercial-fca-compliance-jan-2026.html
sameAs:
  - https://www.linkedin.com/in/declan-sheehy/
keywords: FCA enforcement, FCA fines, compliance, RegTech, AML, Nationwide, Barclays, Monzo, Starling, Consumer Duty, SMCR
schema:
  type: Article
  headline: FCA compliance has left the back office
  datePublished: 2026-01-15
  dateModified: 2026-04-28
  author: Declan Sheehy
  publisher: One Blackwater Consultancy Limited
  about: [FCA enforcement, AML compliance, RegTech, Consumer Duty]
---

# FCA compliance has left the back office

The FCA issued GBP176 million in enforcement fines across 27 actions in 2024, more than triple the GBP53 million recorded in 2023. In 2025 total penalties exceeded GBP124 million. Named firms include Nationwide Building Society (GBP44 million, 2025), Barclays (GBP40 million, 2024 and GBP39.3 million, 2025), Starling Bank (GBP29 million, 2024), Monzo Bank (GBP21.1 million, 2025), Citigroup (GBP28 million, 2024), and the London Metal Exchange (GBP9.2 million, 2025).

## The Pattern Across All Cases

The pattern that runs through every enforcement action is not complexity or bad intent. It is the gap between the pace of business change and the pace of compliance infrastructure investment. Starling and Monzo both grew faster than their controls. Nationwide and Barclays had controls that existed on paper but were not being actively governed. The FCA's message is consistent: documented intent is not enough.

## What the FCA Now Requires

Consumer Duty, SMCR, and GDPR share a common regulatory logic. The FCA wants demonstrated outcomes, not documented intent. The question it asks is not whether you have a policy, but whether you can prove your controls worked when it mattered. Real-time audit trails, unified oversight across communication channels, and governance that connects board accountability to operational controls are what the evidence record now demands.

## The Commercial Argument

Since 2015 the FCA has imposed approximately GBP2.8 billion in total fines on the industry. Growth that outpaces compliance infrastructure is deferred liability. The firms still running 2026 risks on 2015 tools are deciding when, not whether, the bill arrives.