The timeline
- 2020: the FCA begins what court documents describe as sustained supervisory engagement over weaknesses in the firm's controls.
- May 2024: a more detailed review begins, including examination of customer files.
- April 2025: the FCA tells EES its systems and controls are inadequate, particularly onboarding and ongoing monitoring.
- 5 December 2025: the FCA formally requires ten client files, chosen as a representative cross-section.
- 2 June 2026: the FCA requires EES to stop regulated e-money and payment services; interim managers follow on 4 June, and the High Court appoints special administrators on 11 June.
- Mid-September 2026: the FCA opens a formal investigation into whether, between 1 February 2020 and 4 June 2026, EES may have committed offences under the Money Laundering Regulations 2017.
The ten files
The First Supervisory Notice, dated 2 June and published on 2 August, is where the detail sits. As summarised by Securities.io, the FCA found a substantial proportion of the files unreadable, unstructured or hard to access. It assessed all ten as inadequate. Enhanced due diligence was deficient in all six files where it was required, with no source-of-funds or source-of-wealth verification in any high-risk relationship reviewed. A majority of files showed no evidence of required approvals, including senior management or MLRO sign-off.
The screening finding
Screening for politically exposed persons, sanctions and adverse media was deficient in six of the ten files. In one, a customer's name was spelled incorrectly. The FCA also reports finding public, open-source material about an alleged money-laundering scheme and an FBI investigation that the firm had not picked up.
Why one misspelling matters
Screening only works if the name being searched is the name that exists on the list. A typo, a transliteration choice, a reordered family name: each can turn a match into a miss. Fuzzy matching and multilingual name variants exist for exactly that reason. A process that depends on a person typing a name correctly, once, has a single point of failure.
The scale, as alleged
Court filings reported by Bloomberg suggest EES handled about £2 billion for a small group of clients, almost all of it for 14 customers assessed as high-risk, and describe a business that operated more like a correspondent bank than an ordinary payments firm. Those are allegations in filings, not findings.
What to take from an unproven case
A regulator that asks for ten files and receives unreadable ones has already learned something. Evidence that can't be retrieved in a usable form isn't evidence.
Is screening run on verified, normalised name data, and re-run when lists or customer details change?
Does every hit, adverse media included, end in a recorded decision?
If a regulator asked for ten files tomorrow, could you hand over ten complete, readable ones?
Where Finchecker fits
Finchecker's Screening runs PEP, sanctions and adverse media checks in a single pass, built for fuzzy and multilingual name matching, and keeps every result and decision in one audit trail.
Find out what a ten-file review would find in your screening. Talk to Finchecker about sanctions screening for payment providers.
Sources
FCA, "FCA opens investigation into Euro Exchange Securities UK Ltd" (primary): https://www.fca.org.uk/news/enforcement-investigations/fca-opens-investigation-euro-exchange-securities-uk-ltd
Securities.io, summary of the First Supervisory Notice (six of ten files, misspelled name, FBI-related material): https://www.securities.io/fca-probes-euro-exchange-securities-uk-over-money-laundering-rules/
FinanceFeeds, timeline of supervisory engagement: https://financefeeds.com/fca-opens-money-laundering-investigation-into-euro-exchange-securities-uk/
Insurance Journal, Bloomberg report on court filings (client concentration): https://www.insurancejournal.com/news/international/2026/06/23/874808.htm
AML Intelligence, report on the investigation: https://www.amlintelligence.com/2026/09/news-uks-fca-probing-euro-exchange-securities-over-suspected-anti-money-laundering-failings/