Wolfsberg Group’s Guidance on RBA: Is There More We Can Do?
On June 23rd, 2026, the Wolfsberg Group published its updated guidance on the Risk-Based Approach (RBA). While the RBA remains an important concept in preventing financial crime, a few points in particular stood out for deeper analysis.
Growth vs Compliance: A Never-Ending Friction Point for FinTechs
On June 10th, 2026, the Financial Times reported that Revolut’s European Division was restricted from releasing new products by the European Central Bank due to risk, compliance, and legal failures surrounding product launch, highlighting a recurring friction point between growth and compliance for fintechs.
Sterling Stablecoins: A Regulatory Opportunity That Raises More Questions Than Answers
On March 11th, 2026, the FSRC held a meeting to discuss the growth and regulation of a sterling stablecoin. While the advantages are clear and the regulatory framework is developing in the right direction, the KYC framework for holders outside the UK jurisdiction remains the central unresolved question.
Wise: A Compliance-Last Mindset?
On June 1st, 2026, the Bureau of Investigative Journalism revealed that Wise was under investigation for concerns about non-compliance with AML legislation. This is forming a recurring pattern of prior failures, raising the question of whether Wise is building a compliance culture.
The FCA’s Sanctions Review: Strong Controls Mean Nothing Without Governance and Oversight
On May 28th, 2026, the FCA published its review of financial service sanctions systems and controls. The findings reveal a gap in governance and oversight of the overall sanctions framework.
Deutsche Bank’s Sanctions Breach Exposes the Risks of Downstream Customer Oversight
On May 19th, 2026, the Office of Financial Sanctions Implementation (OFSI) fined Deutsche Bank London £165,000 for sanctions breaches related to Russia. The case highlights the risks with downstream customers, as well as the strength of the OFSI’s new settlement scheme.
The FCA’s CDD Review Reveals a Culture Problem. Not a Knowledge Problem
On April 8th, 2026, the FCA released its multi-firm review of CDD, EDD, and ongoing due diligence reviews. The findings display a gap in building a compliance culture rather than a lack of understanding.
Why Rathi’s Case for a System-Wide Fight Against Financial Crime is Right
On May 14th 2026, Nikhil Rathi, the chief executive of the FCA, delivered a speech addressing the ineffectiveness of the current financial crime prevention model and proposed a fundamental shift that may improve it.
The Jorge Figueira Case: How a Professional Money Launderer Exploited the Gaps in AML Systems
In January 2026, Jorge Figueira was indicted by the U.S. Department of Justice for laundering nearly $1 billion. The case exposes gaps in due diligence and the consequences of differences in global AML regulations.
AMLA Tries to Score Against Money Laundering in the Football Sector
On April 27th, 2026, the AMLA Chair, Bruna Szego, expanded on the EU AML regulations, bringing football under the scope. While the RBA approach they are taking is a positive step, their lack of direct supervision and confusion around regulations will cause friction between the clubs, national regulators, and the AMLA.
The FCA’s Principles-Based AI Approach Is Right, But Accountability and Data Privacy Need Specific Rules
On September 8th, 2025, the FCA published its approach to AI in financial markets, opting to rely on existing frameworks to govern the usage. On January 20th, 2026, the Treasury Committee released a report against this approach. I examine why the FCA approach is broadly right, and where regulation is required.
FinCEN’s Proposed AML Reform is Right, But It Has a Structural Problem
On April 7th, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a proposed rule that aims to reform the AML/CFT programs under the Bank Secrecy Act. I analyse the proposed rule, how it may lead to improvements in AML programs, and gaps that need addressing.