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How BaFin Penalized the N26 AML Breach

After a cat and mouse game between N26 and the German BaFin it looks like they’re taking their penalizing of malpractice to a whole new level. While the German challenger seems to be enjoying the high waves of the funding race with rivals like Revolut and Monzo, the same cannot be said about its relationship with the regulators. If you are remotely connected to the payments world, you probably heard about the hefty fine they received over their failing anti money laundering strategy.

But did the BaFin take it a notch too far this time? And how will the challenger navigate the consequences?
neobanks fundings valuations monzo N26 and revolut
Neobanks valuations in 2020, Source: Euromoney

After being appointed a watchdog by the regulators, N26 has now been given a cap on their customer acquisition. In other words, the bank that has been onboarding 170,000 customers every month can now only accept 50 to 70 thousand users monthly until they address issues raised by BaFin.

AML breaches over the years

Banks (both incumbents and challengers) have been notorious for questionable compliance with AML. 

Just to freshen up your memory, ING was fined €3 Million for failures in anti-money laundering regulation earlier this year, only to be followed by ABN AMRO agreeing to pay a whopping €480m for similar violations. Not to mention that ​​Monzo is also under investigation by the British regulator 

Taking AML penalties to the next level

It seems, however,  that these hefty fines weren’t helping with the issue, as banks continue to violate AML rules despite hefty fines. Therefore, the BaFin is putting a limit on customer acquisition this time, which we also suspect to be THE business model of N26.

Customer Acquisition as a Business Model

Looking at this extreme measure, we can't help but wonder about their missing out of potential revenue this could cause. So we believe that the next strategy for N26 to maintain their revenue is to maximize the value of their existing customers. How do you think they could compensate for the lost revenue on customer acquisition?

Finally, it is evident that the German regulators are keeping an extra sharp eye on financial institutions after the recent Wirecard scandal.

Do you think that the BaFin is doing the right thing? Or did they take it a notch too far?

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