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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per year, by date of decision| Period | Cases | Total |
|---|---|---|
| 2022 | 1 | €6.13m |
| 2023 | 6 | €257.2m |
| 2024 | 3 | €145.2m |
| 2025 | 6 | €107.8m |
| 2026 | 3 | €180.9m |
19 cases
3 Aug 2026 UBS Financial Services Inc.FinCEN: 125 million USD against UBS Financial Services as a repeat offender €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.
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.
- FinCEN Assesses Historic $125 Million Penalty Against UBS Financial Services Inc. for Recidivist BSA Violations Press release of an authority
- FinCEN Consent Order Imposing Civil Money Penalty – UBS Financial Services Inc. (Number 2026-02) Decision of an authority
- FinCEN Enforcement Actions Enforcement database of an authority
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 €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.
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 €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.
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.
- Virtual Asset Trading Platform Sentenced for Violating the Travel Act and Other Federal Criminal Charges Press release of an authority
- FinCEN Assesses $3.5 Million Penalty Against Paxful for Facilitating Suspicious Activity Involving Illicit Actors Press release of an authority
- FinCEN Consent Order Imposing Civil Money Penalty – Paxful, Inc. and Paxful USA, Inc. (Number 2025-02) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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9 Dec 2025 Paxful, Inc. und Paxful USA, Inc.FinCEN: USD 3.5 million against crypto platform Paxful for failing to register and AML failures €3.01m
FinCEN imposed a civil money penalty of USD 3.5 million on the peer-to-peer virtual currency trading platform Paxful, Inc. and Paxful USA, Inc. From February 2015 to April 2023 Paxful did not maintain an effective AML programme for its trading platform and hosted wallets and did not report suspicious transactions accurately and on time; the company also allowed its registration as a money services business to lapse and operated unregistered from January 2017 to September 2019 (974 days). Payments of USD 1.75 million to the DOJ are credited against the penalty; USD 1.75 million is payable to FinCEN. The authority allegedly made the findings set out here; this account is not based on a final judgment.
Crypto marketplaces must ensure registration, including timely renewal, customer due diligence and suspicious activity reporting from the outset and keep them in step with growth.
AML duties of crypto platforms: registration, KYC and suspicious activity reporting
- Authority / court
- Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- 31 U.S.C. § 5330, § 5318(h)(1), § 5318(g)(1); 31 C.F.R. §§ 1022.380, 1022.210, 1022.320
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Mitigating circumstances
- FinCEN took into account that Paxful was forthcoming during the investigation, answered information requests completely and on time and agreed to toll the statute of limitations.
Original amount 3,500,000 USD, converted at the ECB reference rate of 9 Dec 2025.
- FinCEN, Consent Order Imposing Civil Money Penalty, In the Matter of Paxful, Inc. and Paxful USA, Inc., Number 2025-02 Decision of an authority
- FinCEN Enforcement Actions Enforcement database of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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20 Nov 2025 Caesars Entertainment, Inc. / Desert Palace, LLC (Caesars Palace)Nevada: 7.8 million USD against Caesars over gambling by an illegal bookmaker €6.77m
On 13 November 2025, the Nevada Gaming Control Board (NGCB) filed a disciplinary complaint for unsuitable methods of operation in connection with an illegal bookmaker and at the same time concluded a settlement of 7.8 million USD with conditions attached to the gaming licences. The conditions relate primarily to improving the AML programme and to additional training and awareness-raising for employees; the Nevada Gaming Commission (NGC) adopted the settlement as its order on 20 November 2025 (Case No. 25-03).
Casino staff must recognise high-risk players and unexplained sources of funds – revenue interests must not override AML obligations.
Checking the source of gambling funds, recognising high-risk customers
Missing or inadequate training played a role in the decision.
- Authority / court
- Nevada Gaming Commission (NGC) auf Beschwerde des Nevada Gaming Control Board (NGCB)
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- Glücksspielrecht Nevada (unsuitable methods of operation)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Other
- Employees
- 10,000 or more
- Mitigating circumstances
- Numerous remedial measures already implemented
- Published
- 13 Nov 2025
Original amount 7,800,000 USD, converted at the ECB reference rate of 20 Nov 2025.
- Nevada Gaming Control Board and Caesars Entertainment, Inc. Enter into Proposed Stipulation for Settlement Regarding Disciplinary Complaint Press release of an authority
- Nevada Gaming Commission – Disposition, November 2025 Agenda (20.11.2025) Decision of an authority
Checked against the official source on 27 Sep 2026 · Version 2 · 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 €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.
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.
- In the Matter of Paxos Trust Company, LLC – Consent Order Decision of an authority
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 €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.
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.
- Consent Order – Wise US, Inc. (Multi-State) Decision of an authority
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 €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.
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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31 Jan 2025 Brink’s Global Services USA, Inc.FinCEN: USD 37 million against Brink's for cash shipments without an AML programme €35.6m
FinCEN imposed a civil money penalty of USD 37 million on Brink’s Global Services USA, Inc. From October 2018 to October 2020 the company transported cash from Mexico to third parties in the United States and Spain, thereby acting as a money services business (MSB), without registering with FinCEN, setting up an AML programme or filing suspicious activity reports; the shipments were equivalent to around USD 800 million. USD 20 million that Brink’s pays to the DOJ under a non-prosecution agreement is credited against the penalty; USD 17 million is payable to FinCEN. The authority allegedly made the findings set out here; this account is not based on a final judgment.
Anyone moving cash across borders for third parties must check whether this triggers registration and reporting duties as a money services business.
Registration and reporting duties for cash transport and money transmission
- Authority / court
- Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- 31 U.S.C. § 5330 und § 5318(h)(1), (g); 31 C.F.R. §§ 1022.380, 1022.210 sowie Pflicht zu Verdachtsmeldungen nach 31 C.F.R. Part 1022
- Action
- Fine
- Status of proceedings
- final
- Sector
- Transport, logistics and shipping
- Mitigating circumstances
- FinCEN took into account that the company cooperated with the authority and agreed to toll the statute of limitations.
- Published
- 6 Feb 2025
Original amount 37,000,000 USD, converted at the ECB reference rate of 31 Jan 2025.
- FinCEN, Consent Order Imposing Civil Money Penalty, In the Matter of Brink’s Global Services USA, Inc., Number 2025-01 Decision of an authority
- FinCEN Announces $37,000,000 Civil Money Penalty Against Brink’s Global Services USA, Inc. Press release of an authority
- FinCEN Enforcement Actions Enforcement database of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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22 Oct 2024 Sahara Dunes Casino, LP (Lake Elsinore Hotel and Casino)FinCEN: 900,000 USD against Lake Elsinore card club over missing reports €831,716
The US Financial Crimes Enforcement Network (FinCEN) imposed 900,000 USD on the Californian card club, which admitted wilful infringements over more than four and a half years: no effective AML programme, missing currency transaction reports (CTR) and suspicious activity reports (SAR), and record-keeping deficiencies. The infringements stemmed from decisions by management.
Even small casinos and card clubs must file currency transaction reports and suspicious activity reports without gaps – management decisions to the contrary are considered wilful.
Currency transaction and suspicious activity reports in gambling operations
- Authority / court
- Financial Crimes Enforcement Network (FinCEN)
- Area of law
- Money laundering and terrorist financing · Suspicious activity reports
- Legal basis
- Bank Secrecy Act (BSA) und Durchführungsbestimmungen
- Action
- Fine
- Status of proceedings
- final
- Sector
- Other
- Culpability
- intentional
- Liability of senior managers
- According to FinCEN, the infringements were based on decisions by management
- Published
- 23 Oct 2024
Original amount 900,000 USD, converted at the ECB reference rate of 22 Oct 2024.
- FinCEN Assesses $900,000 Civil Money Penalty Against Lake Elsinore Hotel and Casino for Violations of the Bank Secrecy Act Press release of an authority
- FinCEN Consent Order – Sahara Dunes Casino, LP d/b/a Lake Elsinore Hotel and Casino (Number 2024-03) Decision of an authority
- FinCEN Enforcement Actions Enforcement database of an authority
Checked against the official source on 28 Sep 2026 · Version 3 · Direct link
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10 Oct 2024 a major Canadian bankFederal Reserve: 123.5 million USD against a major Canadian bank over AML oversight failure €113m
The Board of Governors of the Federal Reserve System imposed 123.5 million USD on a major Canadian bank as 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. The bank 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.
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.
- Federal Reserve, Enforcement Actions (Übersicht) (Entscheidung 2024) Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 3 · Company name anonymised since 10 Oct 2026 · Direct link
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27 Aug 2024 a European major bankNYDFS: USD 35 million against a European major bank for AML failures in foreign branches €31.4m
The NYDFS imposed a penalty of allegedly USD 35 million on a European major bank and its branch in New York. The bank had not maintained an effective AML programme in several foreign branches, had not adequately reviewed correspondent banking and RMA relationships and had not operated adequate transaction monitoring; it also helped customers set up hundreds of offshore accounts.
AML weaknesses in individual foreign units reflect on the whole group and must be managed group-wide.
Group-wide anti-money laundering and due diligence in correspondent banking
- Authority / court
- New York State Department of Financial Services (NYDFS)
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- 3 N.Y.C.R.R. § 116.2; 3 N.Y.C.R.R. § 504.3 (so zitiert); New York Banking Law §§ 39, 44
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 10,000 or more
- Mitigating circumstances
- The NYDFS gave substantial weight to the bank's extensive cooperation during the investigation and its remediation efforts, including substantial investment in compliance resources.
- Published
- 27 Aug 2024
Original amount 35,000,000 USD, converted at the ECB reference rate of 27 Aug 2024.
- New York State Department of Financial Services, Enforcement Actions (Übersicht) (Entscheidung 2024) Enforcement database of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 27 Aug 2026 · Direct link
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16 Oct 2023 a US commercial bankFederal Reserve: USD 14.5 million against US commercial bank over prepaid accounts €13.7m
The Federal Reserve issued a cease and desist order and a civil money penalty of USD 14,478,676 against a US commercial bank. In 2020 the bank opened prepaid card accounts through an external programme manager without adequately verifying applicants' identities under the Customer Identification Program rule, and did not properly oversee this third-party programme. Perpetrators used the accounts with stolen identities to obtain more than USD 300 million in state unemployment benefits.
In fintech partnerships the bank remains responsible for identity verification and fraud prevention, even when a programme manager distributes the accounts.
Identity verification and third-party risk management in fintech programmes
- Authority / court
- Board of Governors of the Federal Reserve System
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- Customer Identification Program Rule, 31 C.F.R. § 1020.220; Federal Deposit Insurance Act (12 U.S.C. § 1818(b) und (i))
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Published
- 19 Oct 2023
Original amount 14,478,676 USD, converted at the ECB reference rate of 16 Oct 2023.
- Board of Governors of the Federal Reserve System, Veröffentlichung der Behörde (Entscheidung 2023) Decision of an authority
Checked against the official source on 8 Oct 2026 · Company name anonymised since 16 Oct 2025 · Direct link
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29 Sep 2023 the US subsidiary bank of a foreign bankFinCEN: USD 15 million against a foreign bank's US subsidiary over monitoring backlogs €14.2m
FinCEN imposed a civil money penalty of allegedly USD 15 million on the US subsidiary bank of a foreign bank. Between April 2016 and March 2021 the bank did not maintain an adequate AML programme, at times built up substantial backlogs in transaction monitoring and did not report suspicious transactions accurately and on time.
Growing alert backlogs in transaction monitoring are a warning sign to which management and the board must respond with additional resources.
Backlogs in transaction monitoring and timely suspicious activity reporting
- Authority / court
- Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury
- Area of law
- Money laundering and terrorist financing · Suspicious activity reports
- Legal basis
- 31 U.S.C. § 5318(h), § 5318(g); 31 C.F.R. §§ 1020.210, 1020.320
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Published
- 29 Sep 2023
Original amount 15,000,000 USD, converted at the ECB reference rate of 29 Sep 2023.
- FinCEN, Enforcement Actions (Übersicht) (Entscheidung 2023) Enforcement database of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 29 Sep 2025 · Direct link
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15 Sep 2023 an international bankFinCEN: USD 15 million against an international bank over correspondent banking and SARs €14.1m
FinCEN imposed a civil money penalty of allegedly USD 15 million on an international bank. Between October 2015 and May 2022 the bank failed to report suspicious transactions, did not maintain an adequate due diligence programme for correspondent accounts of foreign financial institutions and, from March 2021, had no effective AML programme. The bank, which is being wound up, must also surrender its licence.
Correspondent relationships with foreign institutions in high-risk regions require dedicated due diligence that is actually applied, and ongoing monitoring.
Due diligence in correspondent banking relationships in high-risk regions
- Authority / court
- Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- 31 U.S.C. § 5318(g), (h), (i); 31 C.F.R. §§ 1020.320, 1010.610, 1020.210
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Published
- 15 Sep 2023
Original amount 15,000,000 USD, converted at the ECB reference rate of 15 Sep 2023.
- FinCEN, Enforcement Actions (Übersicht) (Entscheidung 2023) Enforcement database of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 15 Sep 2025 · Direct link
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13 Jul 2023 a German major bank and its US entitiesFederal Reserve: USD 186 million against German major bank for delayed AML remediation €166.7m
The Federal Reserve issued a cease and desist order and a civil money penalty of USD 186,392,035 against a German major bank, its branch in New York and US entities. Of this, USD 140,192,035 relates to violations of the supervisory orders of 2015 (sanctions compliance) and 2017 (anti-money laundering), on which the bank had made insufficient progress, and USD 46,200,000 to governance and AML control failures in its former correspondent relationship with the Estonian branch of a Danish major bank, for which the US subsidiary cleared more than USD 267 billion in transactions between 2007 and 2015.
A firm under a supervisory order must demonstrably complete its remediation – lack of progress becomes a ground for sanctions in itself.
Implementing supervisory remediation requirements and correspondent banking risks
- Authority / court
- Board of Governors of the Federal Reserve System
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- Section 8(b) und 8(i)(2) Federal Deposit Insurance Act (12 U.S.C. § 1818); Anordnungen des Board of Governors vom 04.11.2015 und 26.05.2017
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 10,000 or more
- Repeat case
- yes
- Published
- 19 Jul 2023
Original amount 186,392,035 USD, converted at the ECB reference rate of 13 Jul 2023.
- Board of Governors of the Federal Reserve System, Veröffentlichung der Behörde (Entscheidung 2023) Decision of an authority
Checked against the official source on 8 Oct 2026 · Company name anonymised since 13 Jul 2025 · Direct link
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26 Apr 2023 a US trust and custody companyFinCEN: USD 1.5 million against trust company over unfiled suspicious activity reports €1.36m
FinCEN imposed a civil money penalty of allegedly USD 1.5 million on a trust and custody company. Between February 2016 and March 2021 it built up a business line with international customers posing an elevated money laundering risk, but reviewed suspicious activity only manually and filed no suspicious activity report on hundreds of conspicuous transactions.
Anyone expanding into a higher-risk business line must first scale suspicious activity reporting processes to the new volume and risk.
Suspicious activity reporting when expanding into higher-risk business lines
- Authority / court
- Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury
- Area of law
- Money laundering and terrorist financing · Suspicious activity reports
- Legal basis
- 31 U.S.C. § 5318(g); 31 C.F.R. § 1020.320
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 50 to 249
- Mitigating circumstances
- In setting the penalty, FinCEN took the company's financial resources into account.
- Published
- 26 Apr 2023
Original amount 1,500,000 USD, converted at the ECB reference rate of 26 Apr 2023.
- FinCEN, Enforcement Actions (Übersicht) (Entscheidung 2023) Enforcement database of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 26 Apr 2025 · Direct link
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4 Jan 2023 a US financial services firmNYDFS: USD 50 million penalty and compliance requirements for a financial services firm €47.2m
The New York State Department of Financial Services imposed a penalty of allegedly USD 50 million on a US financial services firm because its BSA/AML programme and transaction monitoring were inadequate, it thereby operated in an unsafe and unsound manner, and it did not properly report a cybersecurity incident. In addition, the company committed to further investment in its compliance programme.
If a company grows faster than its compliance, binding obligations to invest in controls may follow alongside fines.
AML programme and cyber incident reporting at financial services firms
- Authority / court
- New York State Department of Financial Services (NYDFS)
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- New York Banking Law §§ 39, 44; Financial Services Law § 408; 23 NYCRR § 200.15, § 504.3, § 500.17; 3 NYCRR § 417.2
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Mitigating circumstances
- The NYDFS treated as mitigating the company's cooperation throughout the investigation, its willingness to enter into a memorandum of understanding (MOU) with the regulator, its engagement with the independent consultant and monitor, and substantial investment in remediating its compliance programme.
- Published
- 4 Jan 2023
Original amount 50,000,000 USD, converted at the ECB reference rate of 4 Jan 2023.
- New York State Department of Financial Services, Enforcement Actions (Übersicht) (Entscheidung 2023) Enforcement database of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 4 Jan 2025 · Direct link
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19 Dec 2022 a US futures commission merchantFutures broker: 6.5 million USD over anti-money laundering and risk limit failures €6.13m
The CFTC fined a futures commission merchant from Minnesota 6.5 million USD. From 2017 to 2020, the firm accepted net margin payments of more than 147 million USD from a customer who controlled a ranching company without adequately investigating the source of the funds or filing a suspicious activity report, and did not enforce trading limits appropriate to the customer's financial resources. The firm also failed to keep certain records of pre-trade communications and did not produce records promptly.
Unusually large payments by a customer call for checks on the source of funds; an anti-money laundering programme must actually be applied to individual accounts.
Checking the source of funds and filing suspicious activity reports
Missing or inadequate training played a role in the decision.
- Authority / court
- U.S. Commodity Futures Trading Commission (CFTC)
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- Section 4g(a) Commodity Exchange Act (7 U.S.C. § 6g(a)); CFTC Regulations 1.11(c)(1), (d), (e)(4), 1.31(b)(4), (d)(3)(ii), 1.73(a)(1), (2), 42.2 und 166.3
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Published
- 20 Dec 2022
Original amount 6,500,000 USD, converted at the ECB reference rate of 19 Dec 2022.
- U.S. Commodity Futures Trading Commission (CFTC), Veröffentlichung der Behörde (Entscheidung 2022) Decision of an authority
Checked against the official source on 8 Oct 2026 · Company name anonymised since 19 Dec 2024 · Direct link