The article is based on the "Agreed Statement of Facts" by the Westminster Magistrates' Court
Fowler Oldfield was a commercial customer of NatWest with a banking relationship that lasted from 2011 to 2016. At the time of onboarding, the responsible relationship manager outlined its business model as follows:
It was a buyer and seller of gold, with plans to purchase assay equipment.
It bought gold using cash obtained from Travelex (a foreign exchange company) on the same day.
The gold was sold the same day under pre-agreed terms, with payments received via electronic transfer.
The Bank would not handle any cash for the business.
Future sales were projected to be £15 million per annum.
Based on this understanding, NatWest initially classified Fowler Oldfield as high-risk.
NatWest's Response on Fowler Oldfield's Changes in Activities
Fowler Oldfield's account activity quickly deviated from its expected business model. Between 2012 and 2016, the company deposited approximately £365 million, with £264 million in cash, across 50 different NatWest branches.
Large volumes of cash began arriving at Fowler Oldfield’s premises, counted using professional money-counting machines, and deposited into NatWest accounts. The amounts were substantial, reaching up to £1.8 million per day.
What was interesting though, is that in 2013, NatWest downgraded the risk rating of Fowler Oldfield to low risk, reducing the level of scrutiny applied to its transactions. The client was classified in 2014 as medium risk and only in 2016 was correctly classified as high-risk. This means that for a period of two years, the bank failed to conduct enhanced monitoring to this high-risk business.
How NatWest Ignored the Red Flags
Several warning signs were ignored by NatWest:
Unprecedented Cash Deposits – Fowler Oldfield’s predicted turnover was £15 million per year. Instead, the company deposited £365 million in under five years.
Scottish Banknotes Deposited Across England – Large volumes of Scottish banknotes were deposited in various NatWest branches in England, an indicator of drug-related money laundering. NatWest was made aware of this by authorities but did not take appropriate action.
Suspicious Deposit Methods – Cash was delivered to NatWest branches in black bin liners, sports bags, and takeaway food containers. The sums deposited were so large that some branches ran out of secure storage space.
Transaction Monitoring System Failures – The bank’s automated system misclassified large cash deposits as cheque deposits, significantly reducing oversight. This occurred due to outdated rule sets that treated deposits at certain branches as lower risk. Approximately £165 million of transactions were affected by this error.
Inexplicable Downgrading of Risk Classification – Despite the high-risk nature of jewellery businesses and the growing cash deposits, Fowler Oldfield’s risk classification was downgraded in 2013. This decision removed key layers of oversight, allowing the laundering to continue unchecked.
Lack of Effective Internal Controls – There was no central mechanism to aggregate warnings from different branches, making it easier for suspicious activity to slip through the cracks. Frontline employees flagged concerns, but no robust escalation framework ensured these reports led to meaningful action.
The Consequences
NatWest’s failures allowed criminals to launder vast amounts of illicit money. Law enforcement was only alerted when a cash-in-transit company flagged concerns in 2016. By then, over £266 million in cash had flowed through Fowler Oldfield’s account in NatWest. Following an extensive investigation, West Yorkshire Police dismantled the operation, and the Financial Conduct Authority (FCA) prosecuted NatWest for failing to comply with anti-money laundering (AML) regulations.
In 2025, four individuals—Gregory Frankel, Daniel Rawson, Haroon "Harry" Rashid, and Arjun Babber—were convicted for their roles in laundering the illicit funds. Their trial at Leeds Crown Court revealed the extent of the operation and how NatWest’s failures facilitated their activities.
The bank was fined £264 million (in 2021), marking the first criminal prosecution of a UK financial institution under money laundering laws. The sentencing judge highlighted that while NatWest was not complicit, its systemic failures made the laundering possible.
Key Takeaways
NatWest’s case demonstrates how systemic weaknesses in compliance can allow large-scale money laundering. To prevent similar incidents, financial institutions must:
Ensure Risk Ratings Reflect Actual Customer Activity – High-risk clients should not be downgraded without thorough reassessment. Risk classification must remain dynamic and responsive to emerging red flags.
Improve Transaction Monitoring to Accurately Classify Deposits – Banks must regularly test and update automated monitoring systems to ensure they correctly classify transactions.
Strengthen Internal Controls and Communication – A central mechanism should consolidate employees concerns from multiple branches to identify suspicious patterns.
Conduct Regular Reviews of High-Cash Businesses – Periodic reviews should validate that a client’s financial activity aligns with its stated business model. Unexplained deviations must trigger immediate scrutiny.
Mandate Proactive Reporting by Branches – Employees must be empowered to escalate concerns beyond their immediate supervisors if red flags are not adequately addressed.
Conclusion
The Fowler Oldfield case demonstrates that financial institutions must remain proactive in detecting and responding to suspicious activity. A failure to act on clear warning signs can have severe consequences, not just financially but also in reputational damage and regulatory action. Financial crime is constantly evolving, and banks must ensure they are not the weak link that enables large-scale money laundering operations to thrive.
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