€3.5m Revolut AML fine – "minor"

Good morning ,

1. Main Story: Revolut fined €3.5m for AML failures

2. Enforcement Actions & Fines: Allianz Global Investors AML fine comes out after 3 years

3. Regulatory Updates: FCA hint at a new FinCrime data tool

1. Revolut fined by Bank of Lithuania - “minor?”

🇱🇹 Lithuania | Bank of Lithuania

Revolut receives €3.5m AML fine (Bank of Lithuania)

During a scheduled inspection the Bank of Lithuania found Revolut had shortcomings in monitoring business relationships and transactions.

However this might not be as big a deal as it seems.

Especially when you look at Bank of Lithuania’s fine calculations.

Match this with the Financial Times reporting that a source close to Revolut stated “the fine represented less than 0.5 per cent of the company’s revenue in 2023, far below the maximum potential fine of 10 percent”. (Financial Times)

Then it’s understandable why this may be seen as minor.

Either way, here’s three talking points for your CEO

1. Administrative Agreements = Emerging Trend in RegTech Diplomacy

   • Why it matters: Lithuania’s approach lets firms address AML issues proactively instead of only dealing with strict penalties

   • Takeaway: Knowing how to engage early can make a big difference

2. Your job is also to understand Enforcement Risk Scoring

   • Why it matters: The fine reflected business scale and the duration/extent of the shortcomings—not just a single misstep

   • Takeaway: Factor in how regulators calculate penalties (revenue size, systemic weaknesses). This broader lens can help you secure internal buy-in and sponsorship for AML initiatives

3. Pan-European MLROs need to watch small jurisdictions closely

   • Why it matters: Lithuania may be a smaller market, but Revolut is large. The resulting enforcement drew wide attention

   • Takeaway: Don’t overlook “small-country” fines; they can pioneer regulatory trends that quickly ripple through the rest of Europe (UK included)

2. Enforcement Actions, Legal Action & Fines

🇨🇭 Switzerland

Swiss Attorney General’s Office teases two ongoing Russian Sanctions cases in their Attorney General Annual Report (Swiss Office of Attorney General)