What a €3.5M AML Fine Teaches Us About Fintech Compliance

In April 2025, Revolut was fined €3.5 million by the Lithuanian Central Bank, a clear example of how an AML fine in fintech can expose deeper issues in compliance frameworks.

To be clear, no confirmed money laundering activity was found. But the deficiencies were significant enough to raise concerns about the effectiveness of the firm’s AML systems.

According to the Lithuanian regulator, the fine was issued due to failures in ongoing transaction monitoring, weaknesses in customer risk assessments, and delays in reviewing and escalating suspicious activity. The bank also noted that Revolut had not fully addressed these issues despite earlier supervisory findings.

I want to be fair here: this is not about criticising Revolut. I’m not here to judge. Revolut is a highly successful fintech, and no system is perfect - especially at scale. But there are important lessons in this case that apply to every fintech operating in a regulated environment.

How About Customer Experience?

Revolut is known for its clean user interface, fast payments, and easy access to financial services. It’s designed to make money management effortless - and for many people, it delivers on that promise.

But if you browse online forums or user reviews, you’ll find a recurring theme:

• Accounts blocked without warning

• Customers unable to access funds

• Slow or no response from support

• Confusion about what triggered the issue

These are all signs that AML systems are in place - but are they effective?

And that’s the key point: a system can be strong, and still not work well. A good AML framework must strike a balance. It should detect suspicious activity, escalate real risks, and act fast. But it must also avoid harming the experience of genuine, legitimate users.

Why the €3.5M AML Fine Should Matter to Every Fintech

The fine handed down to Revolut sends a message that goes beyond Lithuania. Regulators globally are watching these developments closely. As fintechs grow, regulators expect AML controls to evolve, becoming more dynamic, risk-based, and user-aware.

It’s no longer enough to say, “we have a system.” The real question is: does it work in practice? Does it detect risk without creating unnecessary friction for your customers?

How Fintechs Can Build Effective AML and Monitoring Systems

To avoid the pitfalls seen in this case, fintechs need systems that are not only compliant, but also operationally sound and customer-sensitive.

Here’s what that looks like in practice:

• Review Alerts Promptly: Flagging transactions is only the first step. The real test is how quickly and accurately those alerts are reviewed by trained professionals.

• Tailor Controls to Risk Profiles: Create different monitoring rules based on the customer’s risk level, behaviour, geography, and product usage. Uniform rules generate noise and dilute focus.

• Use Smart AI - Not Just Static Rules: Rule-based systems are a start, but modern threats require AI that can detect complex patterns based on real-life laundering typologies. These systems should be explainable, auditable, and constantly improving.

• Human Oversight is Non-Negotiable: Algorithms don’t build trust - people do. Every flagged case should be assessed by someone trained to understand both compliance and context.

• Reduce False Positives Through Ongoing Tuning: A system that flags too much is just as dangerous as one that misses risk. Measure false positives, adjust thresholds, and review outcomes regularly.

• Document Everything Clearly: When regulators review a case, they expect full transparency. Keep an audit trail: what triggered the alert, what actions were taken, and why.

• Invest in Real Support Teams: When something goes wrong for a user, they need answers - not chatbots. Build a customer support function capable of handling AML issues with speed, clarity, and empathy.

AML and Customer Experience: Two Sides of the Same Coin

There’s a myth in fintech that compliance and customer experience are at odds. That if you tighten controls, you’ll alienate users.

But the truth is: strong compliance done right supports trust. It protects users, enhances your credibility, and shows you take their security seriously. The problems start when controls are too rigid, too slow, or too opaque.

The takeaway from this €3.5 million fine isn’t that fintechs should fear enforcement. It’s that they need to design monitoring systems that actually work - for regulators, and for users.

Final Thought

Revolut’s fine is a reminder that no matter how advanced your product or how user-friendly your app, compliance must scale with growth. It’s not just about avoiding fines - it’s about building systems that are smart, fair, and can last over time.