The Platform PM

Rules and risks

Field Guide

Identity and trust: KYB, KYC and ongoing monitoring

07

Rules and risks

2 min read · Chapter 7 of 10

How the rules work

What's written and what's enforced differ, and in 2025-2026 the US and Europe moved in opposite directions.

The US is loosening the paperwork and keeping the penalties. The ownership register shrank to foreign companies. October 2025 guidance dropped automatic 90-day reviews of continuing activity and the need to document decisions not to file a report. FinCEN's April 2026 proposal for AML programs would limit enforcement over upkeep failures to "significant or systemic" ones, and counts AI tools as evidence that a program works. An August 2025 executive order took reputation risk out of bank supervision and put exits on political grounds under scrutiny. Even so, the big penalties kept coming, as the table below shows.

Canada raised the stakes. Maximum FINTRAC penalties rose 40-fold in March 2026, and FINTRAC issued a record 35 penalty notices worth over CAD 247M in 2025-26, mostly against money services businesses.

The EU tightened. From July 10, 2027 the AMLR fixes refresh cycles (one year for high risk, five for the rest), how ownership is calculated, what data you collect on each person (including place of birth and nationality, which US rules don't ask for), and a draft standard makes a government digital ID the preferred way to verify people remotely.

October 2024

Who
TD Bank (US)
Amount
About $3.1B
What triggered it
About 92% of transaction volume never monitored, 2014-2023

October 2024

Who
Starling (UK)
Amount
About £29M
What triggered it
Screened customers against only a fraction of the UK sanctions list; onboarded high-risk customers despite a restriction

January and April 2025

Who
Block (Cash App)
Amount
$80M and $40M
What triggered it
Due diligence, monitoring and a report backlog after rapid growth

July 2025

Who
Monzo (UK)
Amount
About £21M
What triggered it
Onboarded 34,000+ high-risk customers in breach of a restriction while growing from 600,000 to 5.8 million customers

July 2025

Who
Barclays (UK)
Amount
£42M
What triggered it
Onboarding and monitoring of two clients

October 2025

Who
A payments and crypto money services business (Canada)
Amount
About CAD 177M
What triggered it
About 1,000 missed suspicious transaction reports

March 2026

Who
Canaccord Genuity
Amount
$80M
What triggered it
An under-resourced program that missed suspicious activity

April 2026

Who
A payments-heavy New York savings bank
Amount
Order, no fine
What triggered it
Payments growth without proportionate controls; alerts closed automatically

The triggers tell you more than the amounts do. Almost every case here is a program that grew faster than its monitoring, and a weak identity check on its own rarely shows up.

What mistakes cost

Mistakes here get paid for in several ways.

  • Growth. A consent order on your sponsor bank can freeze new onboarding and new products for months while the regulator approves each one.
  • Remediation. Lookbacks, re-verifying existing customers and outside consultants often cost as much as the fine, and the fintech's team does the work. I'd rank this as the costliest one, because when a monitoring program can't keep up, the fix lands on every customer at once.
  • Fraud losses. TransUnion put lenders' exposure to suspected synthetic identities on new US accounts at about $3.3B in the first half of 2025. Whoever extended the credit owns it.
  • Lost customers. Every document request loses applicants, and over-correction after an order (mass exits) hurts good customers, which since 2025 also draws regulatory attention in the US.
  • Penalties and lawsuits. From FTC penalties under INFORM to biometric class actions to billion-dollar bank cases. People are exposed too: TD's case brought prosecutions of employees, and FinCEN started paying whistleblowers up to 30% of sanctions over $1M in 2026.