Read the failure behind the figure
A fine is the outcome of a particular case. It depends on the conduct, applicable powers and circumstances. The examples below concern different firms and different failures; they are not a tariff or a prediction of what another firm would pay.
For a smaller business, the useful question is which weakness in the case could also arise in its own processes.
A missing assessment is a documented gap
The FCA reported in October 2025 that 11% of respondents to a corporate-finance survey lacked a documented business-wide assessment. This was a supervisory finding, not a fine imposed on every respondent. Read the FCA survey
Our practical takeaway: check that a current, identifiable assessment exists and that the firm can retrieve its evidence, review history and approval.
SRA: £25,000 for client and matter assessment failings
In an agreement dated 24 April 2026, BRR Law accepted a £25,000 penalty and £600 investigation costs. The admitted failure concerned client and matter risk assessments between June 2017 and January 2025. The SRA noted remediation and cooperation. Read the SRA decision
Firm-wide assessments and client and matter assessments serve different purposes. The practical lesson is to carry the risk-based approach through to the work on individual files.
FCA: screening controls that failed to keep pace
The FCA’s September 2024 final notice imposed a £28,959,426 penalty on Starling Bank. The case concerned financial crime controls, including sanctions screening, and a breach of a restriction on opening accounts for high-risk customers. Read the FCA final notice
A bank’s penalty is not a cost estimate for an SME. The broader lesson we draw is to test whether controls still cover the business being operated, including after growth or changes to customers and services.
Turn the reading into a useful review
- Check the assessment is current and relevant to the actual business.
- Trace the material risks into procedures and file-level decisions.
- Check the coverage and operation of screening arrangements.
- Give any control gaps an owner and record how they are resolved.
- Keep the evidence of review and challenge.
A tool can help organise this work. The firm still needs to operate, test and review its arrangements.
This guide provides general information, not legal advice. Check the current source material and requirements applicable to your firm. Software does not confer regulatory approval.