On 8 April 2025, the Bank of Lithuania imposed a €3.5 million penalty on Revolut Bank UAB – the largest penalty ever for the neobank – for the deficiencies in its financial crime prevention system. The central bank’s inspection revealed breakdowns in Revolut’s transaction monitoring systems and deficiencies in detecting potentially suspicious activity.
While there was no actual money laundering, the enforcement highlights a theme across the financial sector: that even in the absence of proven financial crime, poor controls and a lack of monitoring can lead to severe regulatory action.
What went wrong for Revolut?
The planned inspection by the Bank of Lithuania revealed a number of shortcomings in Revolut’s anti-money laundering (AML) controls and systems, including:
- Deficiencies in monitoring business relationships and transactions
- Failure to adequately identify suspicious monetary operations or transactions
- Deficiencies in the effectiveness of internal controls over AML requirements
These shortcomings, the Bank stated, compromised the company’s capacity to refer and detect suspicious activity in practice – a basic expectation of any regulated firm dealing with financial services.
The fine of €3.5 million was calculated taking into account the gravity, duration, and geographic scope of the infringements, as well as the gross income of Revolut Holdings Europe, its Lithuanian-based holding company.
This follows a 2022 penalty of €70,000 for delayed accounts and after previous attention of the UK’s Financial Conduct Authority in 2019 on AML compliance. The cumulative record paints a picture of a company that is still developing its control environment in spite of its fast growth and global footprint.
How has Revolut responded?
Following the inspection, Revolut Bank UAB identified the deficiencies and proposed a plan for their elimination. The Bank of Lithuania approved an administrative agreement, citing Revolut’s cooperation and active measures to improve its systems.
A Revolut representative said: “Revolut Bank UAB is committed to the highest standards of regulatory compliance and cooperated with the Bank of Lithuania in taking immediate action to address the procedural deficiencies.”
The regulatory environment is getting tighter
This incident is not just about a Revolut—it’s a warning example for the broader payments and fintech sector. Regulators are increasing their focus on the effectiveness of financial crime prevention measures at companies, especially transaction monitoring, suspicious activity identification, and the governance of such systems.
With increasing regulatory scrutiny and fines that consider not just the presence of failures but also their potential impact, it’s critical that firms don’t wait for a regulatory inspection to uncover weaknesses.
How Neopay can help
At Neopay, we’re experts at helping regulated businesses build, audit, and enhance their compliance frameworks—before the regulators come knocking.
We assist companies:
- Conduct thorough testing of their AML and transaction monitoring controls
- Identify and remediate gaps in business relationship monitoring and ongoing due diligence
- Review governance arrangements and establish robust control structures that are tailored to your risk profile
- Prepare for inspection and minimise enforcement risk through proactive compliance initiatives
Whether you are a growing fintech or a well-established institution, we can assist you in remaining ahead of regulatory expectations and developing systems that are not just compliant, but resilient.
Contact Neopay today to find out how we can assist in your compliance journey.
