Share

cover art for Key Lessons from Monzo’s £21m Fine

The Comply and Outperform Podcast

Key Lessons from Monzo’s £21m Fine

Season 1, Ep. 14

Join Shilo Grayson, Regulatory Strategy Specialist at KYC360, for an examination of the operational, cultural and governance failures that led to Monzo receiving a £21 million FCA fine for serious AML breaches. 


Drawing on her background in the US national security and intelligence community, Shilo breaks down how illicit finance networks exploit weak controls, what Monzo got wrong at each stage of the customer lifecycle, and why similar structural issues have surfaced at other fast-growth digital banks such as Starling Bank. 


Discover how these failures happened, why they persisted, and the practical steps firms can take to scale without repeating the same mistakes. 


More episodes

View all episodes

  • 18. Balancing Sanctions Volatility and Screening Efficiency in 2026

    20:55||Season 1, Ep. 18
    Join Shilo Grayson, Regulatory Strategy Specialist at KYC360, for a focused discussion on balancing sanctions volatility and screening efficiency in 2026. Drawing on her background in the US national security and intelligence community, Shilo explores how rapidly shifting sanctions regimes, increasing divergence globally, and rising enforcement expectations are reshaping sanctions compliance. Secondary sanctions exposure remains widely misunderstood, particularly where indirect ownership and control risks intersect. At the same time, screening teams are under pressure to manage rising alert volumes, reduce false positives and demonstrate a defensible framework to regulators. Name matching alone is no longer sufficient where complex beneficial ownership structures and opaque networks obscure control. This session outlines practical steps to strengthen sanctions screening, manage secondary exposure and maintain operational efficiency in a volatile environment. 
  • 17. Nationwide AML Failures - What Went Wrong?

    33:58||Season 1, Ep. 17
    In December 2025, Nationwide Building Society was fined £44,078,500 by the UK Financial Conduct Authority (FCA) for deficiencies in its financial crime systems and controls. The FCA identified serious weaknesses in Nationwide’s AML framework between 1 October 2016 and 1 July 2021, including shortcomings in customer due diligence, customer risk assessment, and transaction monitoring. Nationwide was also aware that some personal current accounts were being used for business purposes, but lacked an adequate framework to manage the associated risks. One serious case involved a customer who received £27.36m in fraudulent Coronavirus Job Retention Scheme payments, including £26.01m deposited over just eight days. £820,687 remains unrecovered.This podcast explores the FCA’s findings, the specific control gaps that led to significant enforcement action, and the practical lessons for financial institutions.
  • 16. Key KYC/AML Trends to Track in 2026

    28:41||Season 1, Ep. 16
    Drawing on her background in the US national security and intelligence community, Shilo discusses why 2026 is set to be a year of heightened scrutiny for KYC and AML. Customer risk shifts faster than periodic review cycles. Illicit finance is fragmenting into smaller, harder-to-spot flows. Sanctions continue to change quickly, and not always in sync across jurisdictions. AI is accelerating both sides of financial crime, enabling more scalable deception while raising expectations for explainable, auditable AI-powered controls. Discover the consequences of these changes, and the practical steps firms can take to stay ahead in 2026. 
  • 15. Redefining Customer Risk Management with CLM

    23:38||Season 1, Ep. 15
    Join Stephen Platt, Founder and CEO at KYC360, and Tom Devlin, Co-Founder and CCO, for a behind-the-scenes exploration of how Customer Lifecycle Management (CLM) is redefining customer risk management for financial institutions. Discover how KYC360’s CLM solution seamlessly integrates post-onboarding KYC processes, streamlines and automates periodic reviews, and delivers a comprehensive, real-time view of risk throughout every stage of the customer lifecycle. In this exclusive session, we will address pressing operational compliance hurdles associated with traditional periodic review models, highlight common pitfalls such as operational inefficiencies and data silos, and outline innovative strategies to elevate both efficiency and regulatory performance.
  • 13. How and Why the Use of RegTech Is a Competitive Differentiator

    26:40||Season 1, Ep. 13
    Listen to the replay of this standout panel discussion from the KYC360 Conference, moderated by Tom Devlin, CCO and Co-Founder at KYC360 and featuring Peter Messervy Gross, Chief Information Officer at Altum Group; Nadia Lewis, Head of Regulatory Consulting, Jersey at Appleby; and Tamara Vanmeggelen, Chief Risk & Compliance Officer and General Counsel at Mourant. 
  • 12. The Impact of US AML Whistleblowing Legislation on Non-US Businesses

    27:28||Season 1, Ep. 12
    Join Stephen Platt, CEO and Founder of KYC360, and Stephen Kohn, Partner at Kohn, Kohn & Colapinto LLP, for an exclusive replay of their session at the KYC360 Conference, where they share expert insights into the evolution of U.S. whistleblower legislation.A key development in recent years is the recognition by the United States government that corruption undermines much more than personal wealth or efficient markets. In 2022, the US introduced a National Strategy to Counter Corruption globally, a comprehensive initiative involving all major arms of government, including the State Department, Justice Department, Defence Department, and representatives from fifteen federal cabinet offices. Together, they undertook a systematic review of the threat corruption poses.Their conclusion was unequivocal: establishing the fight against corruption is now considered a core United States security interest. This strategy directly links the destabilising effects of corruption, including the erosion of democratic institutions, the spread of authoritarianism and broader societal harm, along with the impact on individuals, who remain the principal victims.
  • 11. Key Lessons from the Cayman FATF Delisting Journey

    21:58||Season 1, Ep. 11
    In this session, non-practising barrister Elisabeth Lees delves into her role leading the Cayman Islands’ national response to the FATF’s fourth-round mutual evaluation. As National Coordinator she led the effort to address the 63 Recommended Actions during the Observation Period and into the de-listing process.  
  • 10. Transforming AML Training in Today's Regulatory Environment

    21:36||Season 1, Ep. 10
    In this session, Bill and Stephen will share key lessons from their decades of experience and explore how organisations can adopt best practices to build a culture of compliance.