Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe and North America: 718 cases from 32 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.

7cases from 1 jurisdiction
€356.3mTotal of monetary amounts
€113mLargest single case: The Toronto-Dominion Bank
€36.1mMedian per case with an amount

Click a bar to drill down one level.

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q3 20230—
Q4 20230—
Q1 20240—
Q2 20240—
Q3 20240—
Q4 20241€113m
Q1 20250—
Q2 20251€36.1m
Q3 20252€26.4m
Q4 20250—
Q1 20262€72.6m
Q2 20260—
Q3 20261€108.4m

7 cases

3 Aug 2026 UBS Financial Services Inc.FinCEN: 125 million USD against UBS Financial Services as a repeat offender USAInternal controls €108.4m

The US Financial Crimes Enforcement Network (FinCEN) imposed 125 million USD on the broker-dealer – the highest BSA penalty against a broker-dealer to date. UBSFS admitted wilful infringements: the AML programme was inadequate, more than 50,000 foreign currency transfers totalling more than 10 billion USD were not adequately monitored and suspicious activity reports were not filed; it is already the second enforcement action after 2018.

What organisations can take from it

Monitoring gaps left unremedied after an earlier enforcement action lead, the second time round, to a multiple of the original penalty.

Authority / court
Financial Crimes Enforcement Network (FinCEN)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Bank Secrecy Act (BSA)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Culpability
intentional
Repeat case
yes
Mitigating circumstances
Up to 15 million USD (remaining amount due by 31 May 2028) may be waived to the extent that UBSFS bears the costs of the independent review of its AML programme and implements its recommendations
Published
3 Aug 2026

Original amount 125,000,000 USD, converted at the ECB reference rate of 3 Aug 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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6 Mar 2026 Canaccord Genuity LLCFinCEN: 80 million USD against Canaccord Genuity over AML and correspondent banking deficiencies USACustomer due diligence €69.2m

The US Financial Crimes Enforcement Network (FinCEN) imposed 80 million USD on the broker-dealer, which admitted wilful BSA infringements: no effective AML programme, no due diligence on correspondent accounts of foreign financial institutions and failure to file suspicious activity reports in connection with securities fraud. Remedial measures that had been promised were not implemented for years.

What organisations can take from it

Implement remedial measures promised in writing to the supervisory authority genuinely and swiftly – years of delay aggravate the later sanction.

Authority / court
Financial Crimes Enforcement Network (FinCEN)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Bank Secrecy Act (BSA)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Published
6 Mar 2026

Original amount 80,000,000 USD, converted at the ECB reference rate of 6 Mar 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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10 Feb 2026 Paxful Holdings Inc.Crypto platform Paxful: 4 million USD penalty after guilty plea to BSA infringements USAInternal controls €3.36m

Following a guilty plea to charges including conspiracy to operate an unlicensed money transmitting business and to violate the AML obligations of the Bank Secrecy Act, the peer-to-peer crypto platform was sentenced to a penalty of 4 million USD. 112.5 million USD would have been appropriate, but the US Department of Justice (DOJ) found an inability to pay; in December 2025, FinCEN had additionally imposed a civil penalty of 3.5 million USD.

What organisations can take from it

Crypto platforms without registration and KYC face criminal liability – up to the limit of their ability to pay.

Authority / court
U.S. Department of Justice
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Travel Act; Verschwörung zum Betrieb eines nicht lizenzierten Geldtransfergeschäfts und zur Verletzung der AML-Pflichten des Bank Secrecy Act
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Mitigating circumstances
Penalty limited from 112.5 million to 4 million USD because of proven inability to pay
Published
11 Feb 2026

Original amount 4,000,000 USD, converted at the ECB reference rate of 10 Feb 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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7 Aug 2025 Paxos Trust Company, LLCNYDFS: 26.5 million USD against Paxos over AML deficiencies in Binance business USA, NYCustomer due diligence €22.8m

The New York State Department of Financial Services (NYDFS) imposed a penalty of 26.5 million USD on the crypto trust company because Paxos did not maintain an effective BSA/AML programme before 2023: KYC checks and risk ratings were inadequate, and transaction monitoring and suspicious activity reporting procedures had gaps, including in connection with the business relationship with Binance, contrary to a 2020 agreement. In addition, Paxos must invest at least 22 million USD in its compliance programme.

What organisations can take from it

Companies that distribute products via partner platforms must include those platforms' customer and transaction risks in their own AML programme.

Authority / court
New York State Department of Financial Services (NYDFS)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
New York Banking Law §§ 39, 44; AML-Vorschriften des NYDFS und Bank Secrecy Act
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
7 Aug 2025

Original amount 26,500,000 USD, converted at the ECB reference rate of 7 Aug 2025.

Checked against the official source on 25 Sep 2026 · Direct link

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9 Jul 2025 Wise US, Inc.Six US states: 4.2 million USD against Wise US over AML programme deficiencies USA, NYSuspicious activity reports €3.59m

In a coordinated multistate proceeding brought by six states – the New York State Department of Financial Services (NYDFS) with the supervisory authorities of CA, MN, NE, TX and MA – the money transmitter must pay 4.2 million USD. An examination (July 2022 to September 2023) found, among other things, a lack of independent AML reviews at an appropriate frequency, late suspicious activity reports, data quality problems in transaction monitoring and unremedied earlier findings; Wise does not admit any legal infringements and must conduct a lookback.

What organisations can take from it

Remedy findings from earlier examinations and audits on time – otherwise they become a ground for sanctions in their own right.

Authority / court
New York State Department of Financial Services (NYDFS) mit den Aufsichtsbehörden von CA, MN, NE, TX und MA
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Bundes- und einzelstaatliches Recht zu Geldtransfer und BSA/AML (u. a. 31 CFR 1022.320)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Remedial measures already initiated and lookback
Published
9 Jul 2025

Original amount 4,200,000 USD, converted at the ECB reference rate of 9 Jul 2025.

Sources

Checked against the official source on 25 Sep 2026 · Direct link

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10 Apr 2025 Block, Inc.NYDFS: 40 million USD against Block (Cash App) over AML deficiencies USA, NYCustomer due diligence €36.1m

The New York State Department of Financial Services (NYDFS) imposed 40 million USD on the operator of Cash App for serious gaps in its BSA/AML programme, including insufficient customer due diligence, a lack of risk-based controls and untimely transaction monitoring. Rapid growth in 2019/2020 led to a considerable backlog of alerts; an independent monitor is being appointed.

What organisations can take from it

Scale compliance capacity with growth – a backlog of alerts is a supervisory infringement in its own right.

Authority / court
New York State Department of Financial Services (NYDFS)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
BSA/AML-, Geldtransfer- und Virtual-Currency-Vorschriften des NYDFS
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
Cooperation and remedial measures already initiated
Published
10 Apr 2025

Original amount 40,000,000 USD, converted at the ECB reference rate of 10 Apr 2025.

Checked against the official source on 25 Sep 2026 · Direct link

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10 Oct 2024 The Toronto-Dominion BankFederal Reserve: 123.5 million USD against Toronto-Dominion Bank over AML oversight failure USAInternal controls €113m

The Board of Governors of the Federal Reserve System imposed 123.5 million USD on the Canadian parent company because it neglected risk management and oversight of its US retail business, so that a US subsidiary was used to launder hundreds of millions of dollars. TD must move the AML programme to the US and commission an independent review of the board and management; the sanctions of all authorities involved (DOJ, FinCEN, OCC) add up to around 3.09 billion USD.

What organisations can take from it

Parent companies are responsible for effective AML oversight of their foreign business – failures there can lead to sanctions running into billions.

Authority / court
Board of Governors of the Federal Reserve System
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
US-Anti-Geldwäschegesetze (laut Federal Reserve)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
Independent review of board and management ordered
Published
10 Oct 2024

Original amount 123,500,000 USD, converted at the ECB reference rate of 10 Oct 2024.

Checked against the official source on 25 Sep 2026 · Direct link

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