Regulatory gap analysis: Nationwide Building Society fined £44m by FCA for AML failings

On 12 December 2025, the Financial Conduct Authority (FCA) fined Nationwide Building Society £44,078,500 for systemic weaknesses in its financial crime controls over a four-and-a-half year period.

The FCA’s Final Notice highlights deficiencies across Customer Due Diligence (CDD), Customer Risk Assessment (CRA) and Transaction Monitoring (TM) and identifies real-world harm arising from failures to detect unusual activity.

Key issues included outdated CDD data, risk models that defaulted most customers to standard risk, monitoring rules that lacked risk sensitivity and failures to respond appropriately to obvious risk indicators, including COVID-19 support payments into personal accounts and unauthorised business use of personal current accounts.

Learn from the FCA’s findings

To help you test your own framework against the FCA’s observations, we’ve created a Regulatory Gap Analysis Template to enable you to:

·       Assess your CDD, CRA and TM controls

·       Identify gaps in design or execution

·       Use open, reflective questions to challenge your current model

·       Support remediation and assurance planning

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