Compliance Radar
Who was sanctioned, and for what?
Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 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.
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Where?
by authority- Hong Kong Monetary Authority (HKMA) €8.39m 100 % · 11 cases
What for?
by topicWho?
by sectorAll sectors
When?
per year, by date of decision| Period | Cases | Total |
|---|---|---|
| 2022 | 1 | €1.44m |
| 2023 | 3 | €2.53m |
| 2024 | 5 | €3.33m |
| 2025 | 2 | €1.1m |
| 2026 | 0 | – |
11 cases
22 Jul 2025 Indian Overseas Bank, Hong Kong BranchIndian Overseas Bank (Hong Kong): HKD 8.5m penalty and orders over monitoring failings €925,553
The Hong Kong branch of Indian Overseas Bank was reprimanded, ordered to pay a pecuniary penalty of 8,500,000 HKD and required to carry out a look-back review of its transaction-monitoring alerts, submit a remedial plan and have its effectiveness assessed by an external adviser. Between May 2021 and January 2024 alerts were not properly followed up, unusual transactions of ten customers were not examined and documented, and senior management did not steer anti-money laundering controls effectively; a competent compliance officer, clear responsibilities and adequate training were lacking.
A monitoring system only protects the bank if senior management ensures that its alerts are handled by competent staff.
Handling monitoring alerts and senior management responsibility for anti-money laundering
Missing or inadequate training played a role in the decision.
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- s. 21(2)(a), (b), (c) AMLO (Cap. 615); Schedule 2 ss. 5(1)(c), 19(3), 23 AMLO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- No previous disciplinary record under the AMLO, cooperation with the regulator.
- Liability of senior managers
- The regulator found that senior management did not take a clear leadership role in anti-money laundering and did not appoint a competent compliance officer; the decision contains no measures against individuals.
- Published
- 22 Jul 2025
Original amount 8,500,000 HKD, converted at the ECB reference rate of 22 Jul 2025.
- HKMA press release: Monetary Authority takes disciplinary actions against three banks for contraventions of AMLO (22.07.2025) Press release of an authority
- HKMA Statement of Disciplinary Action Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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22 Jul 2025 33 Financial Services LimitedHKMA: reprimand and HKD 1.6m for 33 Financial Services over gift card failures €174,222
The HKMA reprimanded the licensed stored value facility provider 33 Financial Services and ordered it to pay a pecuniary penalty of HKD 1.6 million. Between December 2019 and August 2023, a group made up of one corporate and five individual customers bought more than 49,000 gift cards for around HKD 25 million without the firm sufficiently establishing the purpose and nature of the business relationship; for ten customers whom it knew to be buying on behalf of businesses, those businesses were not subjected to due diligence. The firm also failed to ensure that business partners verified and documented the identity of non-Hong Kong resident customers in person.
Gift cards are no exception: anyone evidently buying for a business brings that business in as a customer, and outsourced identity checks must be monitored.
Customer due diligence when selling gift and stored value cards
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- Sections 33Q(2)(a) und 33Q(2)(b)(iii), Section 8Q Payment Systems and Stored Value Facilities Ordinance (Cap. 584) i. V. m. Section 6(2)(b) Part 2 Schedule 3; Guideline on AML/CFT (For Stored Value Facility Licensees)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- yes
- Mitigating circumstances
- Remedial measures to improve controls and cooperation with the HKMA.
- Published
- 22 Jul 2025
Original amount 1,600,000 HKD, converted at the ECB reference rate of 22 Jul 2025.
- Monetary Authority takes disciplinary action against 33 Financial Services Limited for contravention of the PSSVFO Press release of an authority
- Statement of Disciplinary Action – 33 Financial Services Limited Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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6 Dec 2024 China CITIC Bank International LimitedHKMA: HKD 4m fine for China CITIC Bank International over misconfigured rules €485,944
The HKMA imposed a pecuniary penalty of HKD 4 million on China CITIC Bank International because, in the transaction monitoring system it used from November 2015, 13 of 33 detection rules and two core model rules were not implemented as intended until July 2018, so fewer alerts were generated. For 12 of 30 sampled customers, the bank did not examine the background and purpose of unusual transactions. The HKMA identified the lack of a maker-checker control over system values and inadequate acceptance testing as root causes.
The parameters of a monitoring system belong under maker-checker control and must be tested against the business requirements before going live.
Maker-checker controls and testing when configuring monitoring systems
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- Section 21(2)(c) Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615); Sections 5(1)(c) und 19(3) Schedule 2 AMLO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Remedial action, no previous disciplinary record under the AMLO and cooperation with the HKMA.
- Published
- 6 Dec 2024
Original amount 4,000,000 HKD, converted at the ECB reference rate of 6 Dec 2024.
- Monetary Authority takes disciplinary action against China CITIC Bank International Limited for contraventions of the AMLO Press release of an authority
- Statement of Disciplinary Action – China CITIC Bank International Limited Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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8 Nov 2024 Fubon Bank (Hong Kong) LimitedHKMA: HKD 4m fine for Fubon Bank (Hong Kong) over transaction monitoring gaps €477,640
The HKMA imposed a pecuniary penalty of HKD 4 million on Fubon Bank (Hong Kong) because, between April 2019 and July 2022, the bank lacked effective procedures for changes to its transaction monitoring: data transfer from the core banking system was poorly controlled, acceptance tests were ineffective, and there were no procedures for following up a sharp fall in alerts from June 2019 or for regularly reviewing the scope of monitoring. Transactions of around 64,000 customers were not properly scrutinised, and for around 1,500 of them no trigger event review took place after dormant business relationships were reactivated.
A sudden fall in monitoring alerts is itself a warning sign and must be investigated after every system change.
Change management and plausibility checks in transaction monitoring
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- Section 21(2)(c) Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615); Sections 19(3) und 5(1) Schedule 2 AMLO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Self-report, cooperation, remediation of the deficiencies and no previous disciplinary record.
- Published
- 8 Nov 2024
Original amount 4,000,000 HKD, converted at the ECB reference rate of 8 Nov 2024.
- Monetary Authority takes disciplinary action against Fubon Bank (Hong Kong) Limited for contravention of the AMLO Press release of an authority
- Statement of Disciplinary Action – Fubon Bank (Hong Kong) Limited Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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30 Aug 2024 a Hong Kong e-wallet providerE-wallet provider (Hong Kong): HKD 875,000 penalty for customer due diligence gaps €101,209
The e-wallet provider, a stored value facility licensee, must pay a pecuniary penalty of 875,000 HKD. From August 2016 to October 2021 it lacked adequate control systems to repeat customer due diligence upon trigger events and to apply enhanced due diligence in situations presenting a high risk of money laundering and terrorist financing. The company had self-reported the failings.
Wallet providers must reliably turn trigger events into a fresh customer review and treat high-risk cases separately.
Customer due diligence for e-wallets: trigger events and high-risk cases
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- ss. 8Q, 33Q(2)(a) PSSVFO (Cap. 584); Schedule 3 Part 2 s. 6(2)(b) PSSVFO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Self-report, remedial measures, no previous disciplinary record, cooperation.
- Published
- 30 Aug 2024
Original amount 875,000 HKD, converted at the ECB reference rate of 30 Aug 2024.
- Hong Kong Monetary Authority (HKMA), Veröffentlichung der Behörde (Entscheidung 2024) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 30 Aug 2026 · Direct link
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5 Jul 2024 a Hong Kong commercial bankCommercial bank (Hong Kong): HKD 10m penalty for breaches of due diligence duties €1.18m
The commercial bank must pay a pecuniary penalty of 10,000,000 HKD because it breached due diligence duties under the AMLO in various periods between April 2012 and April 2019. Among other things, up to July 2017 it did not verify the identity of 609 persons whom 477 corporate customers had registered as authorisers in its corporate internet banking, did not complete trigger-event reviews for 23 customers, failed to identify suspicious transactions when reviewing transaction-monitoring alerts for 15 customers and did not establish the source of wealth and funds of high-risk customers; record-keeping and procedural failings came on top.
Persons who approve payments on behalf of corporate customers also belong in identity verification.
Customer due diligence in corporate banking and handling of monitoring alerts
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- s. 21(2)(c) AMLO (Cap. 615); Schedule 2 ss. 5(1)(a), 5(1)(c), 15(a), 19(3), 20(3) AMLO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Remedial measures and improved AML controls, no previous disciplinary record under the AMLO, cooperation.
- Published
- 5 Jul 2024
Original amount 10,000,000 HKD, converted at the ECB reference rate of 5 Jul 2024.
- Hong Kong Monetary Authority (HKMA), Veröffentlichung der Behörde (Entscheidung 2024) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 5 Jul 2026 · Direct link
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19 Apr 2024 a Taiwanese commercial bank (Hong Kong branch)HKMA: HKD 9m fine for Taiwanese commercial bank over unreviewed alerts €1.08m
The HKMA imposed a pecuniary penalty of HKD 9 million on the Hong Kong branch of a Taiwanese commercial bank. Between April 2012 and July 2018 most alerts generated by the transaction monitoring system introduced in 2011 went unreviewed; after discovering this in 2018, the bank reviewed more than 2,200 customers and retrospectively filed 304 suspicious transaction reports on 504 customers. In addition, recipient names were missing from a number of cross-border wire transfers between March and July 2018.
A new monitoring system is no substitute for oversight: whether its alerts are actually reviewed must be checked continuously.
Handling of transaction monitoring alerts
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- Section 21(2)(c) Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615); Sections 5(1)(c), 19(3), 12(3) und 12(5) Schedule 2 AMLO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- The bank identified and reported the deficiencies itself, took remedial measures, had no previous disciplinary record under the AMLO and cooperated in the proceedings.
- Published
- 19 Apr 2024
Original amount 9,000,000 HKD, converted at the ECB reference rate of 19 Apr 2024.
- Hong Kong Monetary Authority (HKMA), Veröffentlichung der Behörde (Entscheidung 2024) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 19 Apr 2026 · Direct link
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18 Dec 2023 a Hong Kong e-money providerE-money provider: reprimand and HKD 1.575m penalty for AML and governance failings €185,000
The stored value facility licensee was reprimanded and must pay a pecuniary penalty of 1,575,000 HKD. From February 2019 to mid-July 2020 it lacked adequate transaction-monitoring controls under the AML guideline for SVF licensees, and from August 2016 to August 2020 it lacked sound governance, an effective risk management framework and a robust internal control system. The company therefore did not meet minimum criteria for its licence.
Payment and e-money providers must treat transaction monitoring, governance and internal controls alike as conditions of their licence.
Anti-money laundering and risk management in payment and e-money services
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- ss. 8Q, 33Q(2)(a), 33Q(2)(b)(iii) PSSVFO (Cap. 584); Schedule 3 Part 2 ss. 5(1)(d), 6(2)(b) PSSVFO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Remedial measures (some at the regulator's request), no previous disciplinary record, cooperation.
- Published
- 18 Dec 2023
Original amount 1,575,000 HKD, converted at the ECB reference rate of 18 Dec 2023.
- Hong Kong Monetary Authority (HKMA), Veröffentlichung der Behörde (Entscheidung 2023) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 18 Dec 2025 · Direct link
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15 Aug 2023 a Hong Kong branch of a Swiss private bankPrivate bank (Hong Kong): HKD 16m penalty for inadequate identity and customer checks €1.87m
The Hong Kong branch of a Swiss private bank must pay a pecuniary penalty of 16,000,000 HKD. Despite known red flags, from February 2016 to January 2018 it did not verify in a timely manner the identity of 147 customers transferred from another institution and of their beneficial owners; from April 2012 to October 2018 it also failed to adequately verify the beneficial owners of 33 higher-risk customers, did not terminate 23 of these relationships in time and omitted trigger-event reviews of unusually large transactions of 33 customers.
Anyone taking over a customer book from another institution must promptly carry out its own identity verification, including beneficial owners.
Identifying beneficial owners and handling transferred customer books
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- s. 21(2)(c) AMLO (Cap. 615); Schedule 2 ss. 3(1), 3(3), 3(4)(b), 5(1)(a), 19(3) AMLO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Remedial and enhancement measures, no previous disciplinary record under the AMLO, cooperation with the regulator.
- Published
- 15 Aug 2023
Original amount 16,000,000 HKD, converted at the ECB reference rate of 15 Aug 2023.
- Hong Kong Monetary Authority (HKMA), Veröffentlichung der Behörde (Entscheidung 2023) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 15 Aug 2025 · Direct link
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31 Jan 2023 an Australian major bank (Hong Kong branch)HKMA: HKD 4m fine for Australian major bank over delayed customer reviews €471,154
The HKMA imposed a pecuniary penalty of HKD 4 million on the Hong Kong branch of an Australian major bank because, between June 2016 and May 2017, the bank was late with 121 of 143 periodic customer reviews that fell due, including 58 high-risk customers, 27 of them by more than a year. Although the delays were known, there were no effective procedures to complete the reviews on time.
Known backlogs in customer reviews must be cleared with resources and escalation, particularly for high-risk customers.
Timely periodic review of high-risk customers
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- Section 21(2)(c) Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615); Sections 5(1)(a) und 19(3) Schedule 2 AMLO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Employees
- 10,000 or more
- Repeat case
- no
- Mitigating circumstances
- Deficiencies rectified, no previous disciplinary record under the AMLO and cooperation with the HKMA.
- Published
- 31 Jan 2023
Original amount 4,000,000 HKD, converted at the ECB reference rate of 31 Jan 2023.
- Hong Kong Monetary Authority (HKMA), Veröffentlichung der Behörde (Entscheidung 2023) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 31 Jan 2025 · Direct link
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23 Sep 2022 a Hong Kong branch of a Taiwanese bankBank (Hong Kong): HKD 11m penalty for customer due diligence failings €1.44m
The Hong Kong branch of a Taiwanese bank must pay a pecuniary penalty of 11,000,000 HKD. Between April 2012 and February 2016 it did not effectively review the customer data of 249 customers – trigger-event reviews mostly consisted of a telephone check of a few details – and took no enhanced due diligence measures for 17 high-risk customers, such as senior management approval or establishing the source of wealth and funds. Effective procedures and safeguards against these contraventions were also lacking.
Periodic and trigger-event customer reviews need substance; a brief telephone check does not replace enhanced due diligence for high-risk customers.
Customer due diligence and enhanced due diligence for high-risk customers
- Authority / court
- Hong Kong Monetary Authority (HKMA)
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- s. 21(2)(c) AMLO (Cap. 615); Schedule 2 ss. 5(1)(a), 5(3)(c), 15(b), 19(3), 23 AMLO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Remedial and enhancement measures by the bank, no previous disciplinary record under the AMLO, cooperation with the regulator.
- Published
- 23 Sep 2022
Original amount 11,000,000 HKD, converted at the ECB reference rate of 23 Sep 2022.
- Hong Kong Monetary Authority (HKMA), Veröffentlichung der Behörde (Entscheidung 2022) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 23 Sep 2024 · Direct link