Client Alert: Systems and controls failings lead to criminal charges for UK NatWest Bank

NatWest pleaded guilty on Thursday 7 October 2021 to criminal charges brought by the UK financial services regulator, the Financial Conduct Authority (the “FCA”). The FCA had charged NatWest with failing to properly monitor certain accounts and apply appropriate customer due diligence measures under the UK Money Laundering Regulations 2007 (the “Regulations”). The bank admitted to breaching the regulations in relation to a gold dealership who deposited £365 million ($495 million) in cash into a NatWest account between 2011 and 2016, despite having a predicted turnover of around £15 million. NatWest will be sentenced in December and faces a significant fine. Whilst the FCA has often imposed civil penalties for breaches of the Regulations, this marks the FCA’s first criminal prosecution under the Regulations which were introduced fourteen years ago. The case will likely be of interest to banks and regulated entities but also to other unregulated companies concerned about the growing focus of the UK authorities on criminalising compliance failures.

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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

Client Alert: Systems and controls failings lead to criminal charges for UK NatWest Bank

NatWest pleaded guilty on Thursday 7 October 2021 to criminal charges brought by the UK financial services regulator, the Financial Conduct Authority (the “FCA”). The FCA had charged NatWest with failing to properly monitor certain accounts and apply appropriate customer due diligence measures under the UK Money Laundering Regulations 2007 (the “Regulations”). The bank admitted to breaching the regulations in relation to a gold dealership who deposited £365 million ($495 million) in cash into a NatWest account between 2011 and 2016, despite having a predicted turnover of around £15 million. NatWest will be sentenced in December and faces a significant fine. Whilst the FCA has often imposed civil penalties for breaches of the Regulations, this marks the FCA’s first criminal prosecution under the Regulations which were introduced fourteen years ago. The case will likely be of interest to banks and regulated entities but also to other unregulated companies concerned about the growing focus of the UK authorities on criminalising compliance failures.

To read the full article, please click here.

Related Locations

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

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