Fintech / Banking•Working paper — June 2026•Andréas Hobbelin
AML at Scale — A Case Study Analysis of Revolut
The Structural Limits of Financial Crime Compliance in a Global Fintech
An evidence-based, structural assessment of whether AML/CFT control frameworks can scale at the rate that customer base, transaction volume, product complexity and geographic reach are scaling at the largest European fintechs. Introduces the concept of the AML Capacity Gap.
Scope note. This paper makes no allegation of money laundering, terrorist financing, sanctions violation or criminal wrongdoing by Revolut, by any Revolut entity, or by any individual associated with Revolut. It is a structural and analytical assessment based exclusively on publicly available information. Every substantive claim carries an evidence label: Fact, Evidence-Based Inference, Analytical Opinion, or Open Question.