360° Institutional Intelligence Report
MONZO BANK LIMITED
Reg. 09446231 · GB · active · 17 August 2026
Overview
Coverage statement
Coverage status: PARTIAL. Sources that ran and returned data: Companies House (UK), Google Programmable Search. Sources skipped or not applicable: No PEP screening provider configured. Risk domains NOT reflected in the composite score: PEP. Partial assessment. The following screens did not run and are NOT reflected in the score: PEP.
Why this rating
Derived from the stored score, not written by a model
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Why this rating
Derived from the stored score, not written by a model
45 out of 100 — medium risk, real findings that a reviewer should read before deciding. The number is driven mainly by adverse media and regulatory & enforcement.
This scale runs from 0 to 100 and HIGHER MEANS MORE RISK. 0 would be a counterparty with nothing adverse found by any screen that ran; 100 is the worst case. It is not a quality or credit score, where a high number would be good.
What is driving the number
Adverse Media is high — a substantiated adverse finding.
Regulatory & Enforcement is high — a substantiated adverse finding.
Litigation is elevated — findings exist and are not trivial.
Points shown are each domain's contribution to the composite (its score × the weight actually applied).
What is holding it down
Sanctions & Watchlists, Transparency Risk scored low — these screens ran and found nothing of substance, which is a real result rather than an absence of searching.
What was not checked
1 screen(s) did not run: Politically Exposed Persons. Their weight was redistributed across the domains that did run, so the score reflects only what was actually checked — it is not evidence that those areas are clear.
What would change this rating
- If the adverse media findings were reviewed and dismissed as false positives, the score would fall by roughly 17 point(s).
- If the regulatory & enforcement findings were reviewed and dismissed as false positives, the score would fall by roughly 16 point(s).
- Connecting a provider for Politically Exposed Persons would let that screen run, which could move the score in either direction — that area is currently unmeasured, not clear.
The arithmetic
73 × 22.7% + 79 × 20.4% + 66 × 11.4% + 35 × 6.8% + 5 × 34.1% + 8 × 4.5% = 45/100
Executive summary
Monzo Bank Limited (registered 09446231, active) scored 45/100 — Medium — on a weighted seven-factor model with PARTIAL coverage. The recommended treatment is Standard CDD with Enhanced Monitoring with quarterly monitoring. Note that PEP did not run and are not reflected in this score.
ENTITY IDENTITY & REGISTRATION
1ENTITY IDENTITY & REGISTRATION
Registered name: MONZO BANK LIMITED. Registration number: 09446231. Jurisdiction: GB. Status: active. Type: ltd. Incorporated: 2015-02-18. Registered address: Broadwalk House, 5 Appold Street, London, EC2A 2AG, England. Source: UK Companies House.
BENEFICIAL OWNERSHIP & CONTROL STRUCTURE
2BENEFICIAL OWNERSHIP & CONTROL STRUCTURE
CONFIRMED (authoritative registry): MCCULLAGH, Paul — secretary; BURBIDGE, Eileen — director; DIAS, Valerie Michelle — director; KEELEY, Rupert Graham — director; LAYFIELD, Diana Louise Patricia — director; MCBAIN, Fiona Catherine — director; NEWBERY, Mark — director; PALANIAPPAN, Jambu — director; WICKER-MIURIN, Jane Fields — director.
DECLARED (filed with the registry by the company, NOT independently verified): Monzo Bank Holding Group Limited — Person with Significant Control. Companies House has historically accepted PSC filings without verification, so these entries record what was declared rather than what has been proven.
Note the 25% PSC disclosure threshold: deliberate structuring below it cannot be excluded on the basis of this register.
SANCTIONS & WATCHLIST SCREENING
3SANCTIONS & WATCHLIST SCREENING
Sanctions and watchlist screening returned 3 adverse item(s). • [HIGH] (2025-07-09) UK Challenger Bank, Monzo fined £21 million by FCA for AML ... — http://thefinancialcrimenews.com/uk-challenger-bank-monzo-fined-21-million-by-fca-for-aml-weaknesses/ • [HIGH] (undated) Notice in a nutshell: Bank fined for financial crime failings — https://connections.nortonrosefulbright.com/post/102kv0z/notice-in-a-nutshell-bank-fined-for-financial-crime-failings • [HIGH] (undated) The real lesson from the Monzo fine? Industry's broken approach to ... — https://www.int-comp.org/insight/the-real-lesson-from-the-monzo-fine-industry-s-broken-approach-to-money-laundering-risk-assessment/
These are search-derived findings. They record that a source made a claim; they do not establish it as fact. Allegation, investigation, charge and conviction have not been independently distinguished and require analyst review.
POLITICALLY EXPOSED PERSONS (PEP) ASSESSMENT
4POLITICALLY EXPOSED PERSONS (PEP) ASSESSMENT
PEP screening was NOT performed. No politically-exposed-persons screening provider is connected to this platform. This report therefore makes NO assertion about the PEP, RCA or HIO status of this entity or its controllers. Absence of a PEP finding here must not be read as confirmation that no PEP relationship exists (FATF Recommendation 12; FCA SYSC 12.1). Connecting a screening provider is required before this section can carry any weight.
ADVERSE MEDIA & REPUTATIONAL INTELLIGENCE
5ADVERSE MEDIA & REPUTATIONAL INTELLIGENCE
Adverse media screening returned 6 adverse item(s). • [HIGH] (2025-07-09) UK Challenger Bank, Monzo fined £21 million by FCA for AML ... — http://thefinancialcrimenews.com/uk-challenger-bank-monzo-fined-21-million-by-fca-for-aml-weaknesses/ • [HIGH] (undated) Notice in a nutshell: Bank fined for financial crime failings — https://connections.nortonrosefulbright.com/post/102kv0z/notice-in-a-nutshell-bank-fined-for-financial-crime-failings • [HIGH] (undated) The real lesson from the Monzo fine? Industry's broken approach to ... — https://www.int-comp.org/insight/the-real-lesson-from-the-monzo-fine-industry-s-broken-approach-to-money-laundering-risk-assessment/ • [HIGH] (undated) FCA fines Monzo £21 million for failings in anti-money laundering ... — https://www.mishcon.com/news/fca-fines-monzo-21-million-for-failings-in-anti-money-laundering-systems-and-controls • [HIGH] (undated) PSR publishes first APP scams performance report — https://www.psr.org.uk/news-and-updates/latest-news/news/psr-publishes-first-app-scams-performance-report/ • [HIGH] (undated) Lessons from Monzo Bank's fine for financial crime failings - Lexology — https://www.lexology.com/library/detail.aspx?g=74fe36f4-28d6-42e9-845b-e414d3ef34d1
These are search-derived findings. They record that a source made a claim; they do not establish it as fact. Allegation, investigation, charge and conviction have not been independently distinguished and require analyst review.
REGULATORY & ENFORCEMENT HISTORY
6REGULATORY & ENFORCEMENT HISTORY
Regulatory and enforcement screening returned 4 adverse item(s). • [HIGH] (2025-07-09) UK Challenger Bank, Monzo fined £21 million by FCA for AML ... — http://thefinancialcrimenews.com/uk-challenger-bank-monzo-fined-21-million-by-fca-for-aml-weaknesses/ • [HIGH] (undated) Notice in a nutshell: Bank fined for financial crime failings — https://connections.nortonrosefulbright.com/post/102kv0z/notice-in-a-nutshell-bank-fined-for-financial-crime-failings • [HIGH] (undated) FCA fines Monzo £21 million for failings in anti-money laundering ... — https://www.mishcon.com/news/fca-fines-monzo-21-million-for-failings-in-anti-money-laundering-systems-and-controls • [HIGH] (2025-07-23) Financial crime controls in the spotlight – lessons learned in relation ... — https://www.regulationtomorrow.com/2025/07/financial-crime-controls-in-the-spotlight-lessons-learned-in-relation-to-fca-supervisory-powers-and-expectations/
These are search-derived findings. They record that a source made a claim; they do not establish it as fact. Allegation, investigation, charge and conviction have not been independently distinguished and require analyst review.
LITIGATION & LEGAL PROCEEDINGS
7LITIGATION & LEGAL PROCEEDINGS
Litigation screening returned 2 adverse item(s). • [HIGH] (undated) Notice in a nutshell: Bank fined for financial crime failings — https://connections.nortonrosefulbright.com/post/102kv0z/notice-in-a-nutshell-bank-fined-for-financial-crime-failings • [HIGH] (2025-07-09) UK Challenger Bank, Monzo fined £21 million by FCA for AML ... — http://thefinancialcrimenews.com/uk-challenger-bank-monzo-fined-21-million-by-fca-for-aml-weaknesses/
These are search-derived findings. They record that a source made a claim; they do not establish it as fact. Allegation, investigation, charge and conviction have not been independently distinguished and require analyst review.
FINANCIAL PROFILE & SOURCE OF WEALTH
8FINANCIAL PROFILE & SOURCE OF WEALTH
Financial screening ran and returned no adverse findings. Sources consulted: Google Programmable Search. This is a meaningful clean result rather than an absence of checking.
GEOGRAPHIC & JURISDICTIONAL RISK
9GEOGRAPHIC & JURISDICTIONAL RISK
Jurisdiction: GB. Jurisdiction risk scored 35/100. This score derives from published reference data (FATF listings, EU high-risk third countries, Transparency International CPI) held in the platform's reference tables. Where a jurisdiction is absent from those tables it is scored conservatively rather than favourably.
ESG & CONDUCT RISK
10ESG & CONDUCT RISK
No dedicated ESG data source is connected. Environmental, labour, human rights, governance, whistleblower, supply chain and data breach risk have NOT been separately screened. Any ESG-relevant items appearing above arose incidentally from general adverse media searching.
COMPOSITE RISK ASSESSMENT
11COMPOSITE RISK ASSESSMENT
Composite risk score: 45/100 — Medium. Coverage: PARTIAL. Factor scores and the weights actually applied (renormalised across the domains that ran, so they sum to 100%): • SANCTIONS: 5/100 × 34.1% • ADVERSE_MEDIA: 73/100 × 22.7% • REGULATORY: 79/100 × 20.4% • LITIGATION: 66/100 × 11.4% • JURISDICTION: 35/100 × 6.8% • TRANSPARENCY: 8/100 × 4.5% Domains NOT reflected in this score: PEP. Weights version: v1.0.0.
CUSTOMER DUE DILIGENCE RECOMMENDATION
12CUSTOMER DUE DILIGENCE RECOMMENDATION
CDD level: Standard CDD with Enhanced Monitoring. EDD required: NO. Monitoring frequency: QUARTERLY. Outstanding information gaps: PEP. These must be closed before this recommendation can be considered complete. Trigger events for immediate review: any new sanctions designation, a change of beneficial ownership or control, a change of company status, or any regulatory enforcement action.
Sources & method
Sources
34 cited · 11 read in full · 7 source call(s)
Every URL behind a finding in this report. “Read in full” means the page itself was retrieved and classified on its whole text rather than on a search snippet; those carry a SHA-256 hash of exactly what was read, so the evidence can be shown to be unaltered later.
Screens run against this entity
A source marked FAILED or skipped was not checked. No conclusion may be drawn from its silence, and its weight was excluded from the score rather than counted as a pass.
13DATA SOURCES & METHODOLOGY
Date of assessment: 18 August 2026. Sources consulted and their outcomes: • Companies House (UK) [REGISTRY] → OKDATA • Companies House (UK) [UBO] → OKDATA • Google Programmable Search [SANCTIONS] → OKDATA • Google Programmable Search [ADVERSEMEDIA] → OKDATA • Google Programmable Search [FINANCIAL] → OKDATA • Google Programmable Search [LITIGATION] → OKDATA • Google Programmable Search [REGULATORY] → OKDATA • No PEP screening provider configured [PEP] → SKIPPED
OKDATA = the source ran and returned data. OKEMPTY = the source ran and genuinely found nothing, which is a meaningful clean result. FAILED = the source did not run; no conclusion may be drawn from its silence. SKIPPED = not applicable to this jurisdiction, or no provider is configured.
Coverage status: PARTIAL. Sources that ran and returned data: Companies House (UK), Google Programmable Search. Sources skipped or not applicable: No PEP screening provider configured. Risk domains NOT reflected in the composite score: PEP. Partial assessment. The following screens did not run and are NOT reflected in the score: PEP.
Legal frameworks: FATF Recommendations; UK Money Laundering Regulations 2017; FCA SYSC 6.3; EU 6AMLD.
This report was produced by an AI-assisted due diligence engine from publicly available sources. It does not constitute legal advice. The engaging firm retains responsibility for final compliance determinations.
Execution logs
Execution logs
47 entries