AML Compliance
Digital bank Revolut has introduced a gamified points-based system known as “Karma”, designed to track and reward employee behaviour linked to compliance and risk management. The initiative reflects a growing trend across banking and fintech: that culture is as critical as technology in building resilient anti-financial crime frameworks.
How the Karma System Works
The Karma platform uses a points-based model that directly influences employee bonuses. Points are awarded or deducted based on how teams adhere to over 30 risk and compliance processes, ranging from onboarding checks to operational protocols.
Unlike traditional performance reviews, Karma functions at a team level. Collective scores are used to adjust individual bonuses upward or downward, ensuring that compliance becomes a shared responsibility rather than an isolated function.
What Karma Actually Rewards
Revolut’s system isn’t about external AML tools. It’s about internal compliance behaviours.
According to company disclosures and media reporting, Karma rewards and penalises:
Adhering to compliance processes → Following AML onboarding and due diligence rules earns points.
Raising or responding to risk alerts → Staff are incentivised to escalate suspicious activity rather than overlook it.
Proactive engagement → Completing compliance training or policy refreshers early is rewarded.
Team accountability → Points are aggregated across teams, creating peer responsibility for compliance standards.
Failure to comply → Non-adherence to processes or risky decisions reduces points and can reduce bonuses.
Since its rollout, Revolut claims the Karma system has led to a 25% improvement in company-wide compliance performance, reinforcing its effectiveness as a cultural driver.
Why Culture Matters in Compliance
Both the Financial Conduct Authority (FCA) and the European Banking Authority (EBA) emphasize that a healthy firm culture is central to effective compliance. The FCA notes, “culture drives conduct and decision-making,” and links cultural weaknesses to many instances of regulatory failure.
The EBA, through its public materials on internal governance consultation, calls for "specific procedures for assessing compliance" and "prior assessment and approval by the compliance function", highlighting that culture and process rigor must be embedded institution-wide.
The Role of Gamification in Compliance Culture
Academic research suggests that gamification can increase employee engagement and encourage ethical behaviour when used to reinforce compliance objectives. For example, a 2024 study in the Journal of Business Ethics highlights that gamified systems can motivate positive behaviours but must be carefully designed to avoid unintended consequences. Poorly implemented schemes risk encouraging staff to chase points rather than genuinely prioritise risk awareness and compliance.
Balancing Incentives With Oversight
While Karma demonstrates innovation, compliance experts caution that systems alone cannot replace accountability. Under the UK’s Senior Managers and Certification Regime (SMCR), senior leaders must still demonstrate they have active oversight of compliance risks, not simply delegate responsibility to scoring models.
This means Karma should be seen as a complementary tool, reinforcing behaviour at the ground level, while leadership sets the tone from the top.
Compliance as a Competitive Advantage
Revolut’s Karma experiment signals a wider shift: compliance is moving from cost centre to competitive advantage. Fintech's under increasing regulatory scrutiny are finding that embedding compliance into culture can win trust from regulators, customers, and investors alike.
For firms in similar positions, pairing culture-driven initiatives like Karma with advanced RegTech tools such as Alert Adjudication for alert resolution and FacctShield, for transaction monitoring, can create a robust, end-to-end compliance framework.





