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.

293cases from 38 jurisdictions
€2.42bnTotal of monetary amounts (272 cases with an amount)
€272.8mLargest single case: two Australian casino operators
€500,000Median per case with an amount

Click a bar to drill down one level.

When?

per year, by date of decision
Trend
PeriodCasesTotal
202213€394m
202358€683m
202461€369.1m
2025108€690.8m
202653€281.6m

293 cases

16 Sep 2026 Wallester ASFinancial supervisor orders Wallester to remedy governance and AML deficiencies EstoniaInternal controls Order

Following an on-site inspection, the Finantsinspektsioon (Estonian Financial Supervision Authority) issued an order requiring the payment institution Wallester to remedy, by 31 December, deficiencies in governance and control functions (separation of the lines of defence, internal rules), in safeguarding customer funds and in the staffing of its anti-money laundering and counter-terrorist financing function. Date = publication of the press release.

What organisations can take from it

Fast-growing payment service providers must let their compliance, AML and internal audit functions grow with them in terms of staffing and organisation.

Authority / court
Finantsinspektsioon (Estnische Finanzaufsicht)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Aufsichtsrechtliche Anordnung (ettekirjutus) der Finantsinspektsioon
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Published
16 Sep 2026

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

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11 Sep 2026 Capitec Bank LimitedCapitec Bank: ZAR 28m for failings in customer due diligence and training South AfricaCustomer due diligence €1.49m

Following a 2023 inspection, the supervisor found inadequate customer due diligence and inadequate enhanced and ongoing due diligence in sampled files, no ongoing training for sampled employees and gaps in the risk management and compliance programme, such as name and payment screening manuals that had not been approved by management before being implemented, and inadequately documented arrangements for terrorist property reporting and financial sanctions. Five cautions and penalties of 28 million ZAR were imposed, of which 5.5 million ZAR is suspended for 36 months from 13 October 2025; the bank had already been sanctioned with 56.25 million ZAR in December 2024. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

A bank that has already been sanctioned will be judged at the next inspection on full implementation – due diligence and training must demonstrably be in place.

Relevance to training and awareness

Ongoing due diligence and regular anti-money laundering training

Missing or inadequate training played a role in the decision.

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Sections 21, 21A und 21C i. V. m. 42(1), 42(2)(d), (e), (g) sowie Sections 42 und 43 Financial Intelligence Centre Act 38 of 2001
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
Cooperation in remedying the deficiencies; 5.5 million ZAR suspended for 36 months.
Published
11 Sep 2026

Original amount 28,000,000 ZAR, converted at the ECB reference rate of 11 Sep 2026.

Checked against the official source on 4 Oct 2026 · Direct link

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31 Aug 2026 EM@NEY P.L.C.Malta: EM@NEY pays 97,622 EUR under settlement for late bank account register reports MaltaMoney laundering and terrorist financing €97,622

The financial institution did not deliver on time the data due every seven days to the Centralised Bank Account Register (CBAR). The Financial Intelligence Analysis Unit (FIAU) set a fine of 162,704 EUR, which was reduced by 40% to 97,622 EUR under a settlement pursuant to its 2026 settlement policy.

What organisations can take from it

Recurring mandatory reports need deadline monitoring with escalation – otherwise individual omissions add up to six-figure sums.

Authority / court
Financial Intelligence Analysis Unit (FIAU)
Area of law
Money laundering and terrorist financing
Legal basis
Reg. 4(2), 8, 9 CBAR Regulations (S.L. 373.03)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Settlement with 40% reduction
Published
4 Sep 2026

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

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27 Aug 2026 MiFinity Malta LimitedMalta: MiFinity pays 160,099 EUR following anti-money laundering examination MaltaCustomer due diligence €160,099

At the payment institution, the customer risk assessment had only been introduced after business had started, some customers remained unassessed, and customer profiles were based on transaction thresholds rather than on risk. The Financial Intelligence Analysis Unit (FIAU) set a fine of 266,833 EUR and a follow-up directive; under a settlement, the fine was reduced by 40% to 160,099 EUR.

What organisations can take from it

A customer risk assessment belongs before business starts, not in a later remediation project.

Relevance to training and awareness

Risk-based customer profiles and source of funds

Authority / court
Financial Intelligence Analysis Unit (FIAU)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Reg. 2(1), 5(5)(a)(ii), 7(1)(c), 7(2)(a), 21, 22 PMLFTR
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Settlement with 40% reduction; remediation demonstrated
Published
2 Sep 2026

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

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25 Aug 2026 Wise Europe SAWise Europe: NBB order and public statement over customer due diligence failures BelgiumCustomer due diligence Order

The Banque nationale de Belgique (National Bank of Belgium) found serious anti-money laundering due diligence failures at Wise Europe SA, including in identifying and verifying customers and beneficial owners, ongoing monitoring of business relationships, analysis of atypical transactions and intra-group information sharing. It made public that Wise Europe had not complied with an order of 8 July 2025 to meet these obligations by 31 March 2026, and ordered full compliance by 31 January 2027 at the latest; no fine was published.

What organisations can take from it

Letting a supervisory deadline to remedy KYC failures lapse risks new orders and public naming.

Relevance to training and awareness

KYC and transaction monitoring at payment service providers

Authority / court
Banque nationale de Belgique / Nationale Bank van België (BNB/NBB)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 13 § 1, 23, 26, 27, 35 § 1 und 45 Gesetz vom 18. September 2017 zur Verhinderung von Geldwäsche; Anordnung nach Art. 93 § 1 1°, Veröffentlichung nach Art. 93 § 2 1° und Art. 98/1 i. V. m. 135 § 3
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Published
25 Aug 2026

Checked against the official source on 2 Oct 2026 · Direct link

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21 Aug 2026 Bank oder Finanzinstitut (anonymisiert)Liechtenstein: CHF 50,000 fine for due diligence and sanctions screening failures LiechtensteinCustomer due diligence €53,459

The Finanzmarktaufsicht (FMA, Liechtenstein Financial Market Authority) fined an unnamed legal person CHF 50,000 for breaches of the Sorgfaltspflichtgesetz (Due Diligence Act) – business profiles not established or updated as required, group-wide application of the due diligence standard not ensured – and of the Gesetz über die Durchsetzung internationaler Sanktionen (ISG, Act on the Enforcement of International Sanctions). The ISG provision relied on makes it an offence punishable by a fine not to carry out the sanctions screening of customer and transaction documents, or to carry it out improperly or late.

What organisations can take from it

Sanctions screening of customers and transactions must be complete and timely, and in groups the due diligence standard must also be applied at branches and subsidiaries.

Relevance to training and awareness

Sanctions screening of customers and transactions and group-wide due diligence standards

Authority / court
Finanzmarktaufsicht Liechtenstein (FMA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 31 Abs. 1 Bst. e und k Sorgfaltspflichtgesetz (SPG); Art. 11 Abs. 1a Bst. c Gesetz über die Durchsetzung internationaler Sanktionen (ISG)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 50,000 CHF, converted at the ECB reference rate of 21 Aug 2026.

Checked against the official source on 28 Sep 2026 · Direct link

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20 Aug 2026 QuinnBet (Gibraltar) LimitedQuinnBet: £415,986 over anti-money laundering and financial vulnerability check failings United KingdomInternal controls €485,256

The operator of quinnbet.com will pay £415,986 in lieu of a financial penalty to the Consolidated Fund (the UK Government's general account) under a settlement and contribute to the Commission's investigation costs. The settlement also includes a disgorgement of £193,118, which is not included in the amount shown. A compliance assessment found breaches of the anti-money laundering licence condition LC 12.1.1 paras. 2 and 3 (March 2023 to August 2025) and of the customer interaction requirements under SRCP 3.4.3; following an error during a platform migration, some of the required financial vulnerability checks under SRCP 3.4.4 were also not carried out between February and May 2025. It is the first enforcement action against the company.

What organisations can take from it

Financial vulnerability checks are a licence requirement that must continue without gaps, including during technical changeovers.

Relevance to training and awareness

Financial vulnerability checks and AML controls in online betting

Authority / court
Gambling Commission
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
s. 116 Gambling Act 2005; LC 12.1.1 Abs. 2 und 3, SRCP 3.4.3 und SRCP 3.4.4 Abs. 1 der Licence Conditions and Codes of Practice (LCCP)
Action
Fine
Status of proceedings
final
Sector
Other
Repeat case
no
Mitigating circumstances
No previous enforcement action, a swift action plan, full cooperation, early voluntary reporting of some of the failings, voluntary divestment of the funds gained from them and early acceptance of the failings.
Published
20 Aug 2026

Original amount 415,986 GBP, converted at the ECB reference rate of 20 Aug 2026.

Checked against the official source on 3 Oct 2026 · Direct link

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12 Aug 2026 Banco Genial S.A.Banco Genial: BRL 21.56m for anti-money laundering failings in FX business BrazilCustomer due diligence €3.62m

The Comitê de Decisão de Processo Administrativo Sancionador (COPAS, sanctions decision committee) of the Banco Central do Brasil (Brazilian central bank) fined Banco Genial S.A. a total of BRL 21,560,000.00: BRL 4,200,000.00 for inadequate anti-money laundering policies, procedures and controls, BRL 8,920,000.00 for failing to verify the credentials of foreign exchange clients and BRL 8,440,000.00 for failing to file suspicious activity reports with the financial intelligence unit Coaf in the proper form and on time. According to the case documents, the reporting charge concerned 1,364 foreign exchange transactions for the acquisition of virtual assets with five clients between November 2020 and October 2021, totalling USD 744,341,982.45.

What organisations can take from it

Foreign exchange transactions for buying crypto-assets require checks on clients' financial capacity and timely suspicious activity reports.

Relevance to training and awareness

Customer due diligence and suspicious activity reporting in FX and crypto business

Authority / court
Banco Central do Brasil (Comitê de Decisão de Processo Administrativo Sancionador – COPAS)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Lei nº 9.613/1998, Art. 10 III, Art. 11 und 12; Lei nº 13.506/2017; Circular BCB nº 3.978/2020; Resolução CMN nº 3.568/2008
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.

Original amount 21,560,000 BRL, converted at the ECB reference rate of 12 Aug 2026.

Checked against the official source on 3 Oct 2026 · Direct link

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11 Aug 2026 Panzer Norge ASPanzer Norge AS: NOK 100,000 for AML failures at an accounting firm NorwayCustomer due diligence €9,115

Finanstilsynet (Norwegian Financial Supervisory Authority) fined the accounting firm Panzer Norge AS, based in Alta, NOK 100,000 under the Anti-Money Laundering Act. The inspection found shortcomings in the firm-wide risk assessment and in customer due diligence, as well as further breaches in risk and quality management and in engagement agreements; the company, which had five employees, essentially did not dispute the breaches.

What organisations can take from it

Small accounting firms are also subject to anti-money laundering obligations and need a documented risk assessment and demonstrable customer due diligence for every engagement.

Relevance to training and awareness

Anti-money laundering obligations for accounting and advisory firms

Authority / court
Finanstilsynet
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§§ 7, 8, 9, 12 Abs. 4, 13 Abs. 1, 3 und 4, 14, 24 und 49 hvitvaskingsloven
Action
Fine
Status of proceedings
unknown
Sector
Other
Employees
Under 50
Culpability
negligent
Published
17 Sep 2026

Original amount 100,000 NOK, converted at the ECB reference rate of 11 Aug 2026.

Checked against the official source on 28 Sep 2026 · Direct link

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10 Aug 2026 Your Neighbourhood Credit Union LimitedFINTRAC: CAD 16,500 penalty on Your Neighbourhood Credit Union Limited for one violation of anti-money laundering obligations CanadaInternal controls €10,243

According to FINTRAC, Your Neighbourhood Credit Union Limited is a provincially regulated credit union based in Kitchener, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 16,500 on the company on 10 August 2026. According to FINTRAC's findings, made during a compliance examination, the company committed one violation of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violation concerned written compliance policies and procedures. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Your Neighbourhood Credit Union Limited", published 24 September 2026, https://fintrac-canafe.canada.ca/pen/amps/pen-2026-09-24-2-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 9.6(1); PCMLTF Regulations 156(1)(b); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
24 Sep 2026

Original amount 16,500 CAD, converted at the ECB reference rate of 10 Aug 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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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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27 Jul 2026 Banque Lombard Odier & Cie SAFederal Criminal Court fines Banque Lombard Odier CHF 3 million over money laundering SwitzerlandInternal controls €3.23m

The Bundesstrafgericht (Federal Criminal Court) found Banque Lombard Odier & Cie SA guilty of failing to take adequate organisational measures against aggravated money laundering by a former relationship manager who in 2011 and 2012 handled accounts of a criminal organisation holding proceeds of corruption in the Uzbek telecommunications market; despite warning signs, the bank's anti-money-laundering functions did not sufficiently ensure that the origin and purpose of the funds were investigated and documented. The bank was fined CHF 3,000,000 and bears procedural costs of CHF 24,561.49; it was acquitted on the remaining charges, and proceedings for acts before 27 July 2011 were dismissed as time-barred. The judgment is not final.

What organisations can take from it

Warning signs about the origin of large inflows must be investigated and documented by the anti-money-laundering function itself, not just by the relationship manager.

Relevance to training and awareness

Anti-money-laundering: investigating conspicuous inflows and documentation

Authority / court
Bundesstrafgericht (Strafkammer), Anklage der Bundesanwaltschaft
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 102 Abs. 2 StGB i.V.m. Art. 305bis Ziff. 1 und 2 StGB (Urteil SK.2023.42)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The long time elapsed since the offences (2011/2012) was taken into account as mitigating.
Published
27 Jul 2026

Original amount 3,000,000 CHF, converted at the ECB reference rate of 27 Jul 2026.

Checked against the official source on 2 Oct 2026 · Direct link

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24 Jul 2026 The New Brunswick Lotteries and Gaming CorporationFINTRAC: CAD 399,712.50 penalty on The New Brunswick Lotteries and Gaming Corporation for one violation of anti-money laundering obligations CanadaSuspicious activity reports €249,415

According to FINTRAC, The New Brunswick Lotteries and Gaming Corporation is a reporting entity in the casino sector based in Fredericton, New Brunswick. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 399,712.50 on the company on 24 July 2026. According to FINTRAC's findings, made during a compliance examination, the company committed one violation of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violation concerned suspicious transaction reporting. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on the New Brunswick Lotteries and Gaming Corporation", published 3 September 2026, https://fintrac-canafe.canada.ca/pen/amps/pen-2026-09-03-2-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7; Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Other
Published
3 Sep 2026

Original amount 399,712.5 CAD, converted at the ECB reference rate of 24 Jul 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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24 Jul 2026 Shelbit General Trading L.L.CVARA sanctions Shelbit again for unlicensed crypto services, missing KYC and promotion United Arab EmiratesCustomer due diligence Fine

Despite a cease-and-desist notice and enforcement action of 2 January 2025, the Virtual Assets Regulatory Authority (VARA, Dubai's virtual assets regulator) found that Shelbit General Trading L.L.C (Shelbit Exchange) continued to provide virtual asset services in and from Dubai without a licence, onboarded users without the mandatory KYC checks and promoted its services without authorisation. VARA again imposed fines of an undisclosed amount and ordered it to cease immediately; according to the regulator, the risk identified also concerned cross-border transactions with possible consequences for the integrity of the UAE financial system.

What organisations can take from it

Disregarding a cease-and-desist order leads to further sanctions – the regulator keeps monitoring the market after the first action.

Relevance to training and awareness

Compliance with cease-and-desist orders and KYC obligations

Authority / court
Virtual Assets Regulatory Authority (VARA), Dubai
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Federal Decree-Law No. (10) of 2025 (AML/CFT/PF); Cabinet Resolution No. (111) of 2022; Dubai Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai; VARA Regulations and Rulebooks
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Published
24 Jul 2026

Checked against the official source on 3 Oct 2026 · Direct link

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23 Jul 2026 Evolution Malta Holding LimitedEvolution: £4.75m because its own games ran on unlicensed sites accessible in GB United KingdomInternal controls €5.57m

The games supplier will pay £4,750,000 in lieu of a financial penalty under a regulatory settlement, contribute to the Commission's investigation costs and accept an additional licence condition requiring an independent audit within twelve months. Five genuine Evolution games were accessible at scale to consumers in Great Britain via six websites of two operators not licensed by the Gambling Commission; between April 2024 and January 2025, its risk assessment and its anti-money laundering policies and controls did not adequately address risks arising from business partners in particular (LC 12.1.1, LC 12.1.2). After the Commission notified it in December 2024, Evolution immediately and permanently blocked the games for users in Great Britain.

What organisations can take from it

B2B suppliers must monitor where their products are actually offered and stop their use by unlicensed operators.

Relevance to training and awareness

Control over the distribution of own products to unlicensed operators

Authority / court
Gambling Commission
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
s. 116 Gambling Act 2005; LC 12.1.1 Abs. 1–3 und LC 12.1.2 der Licence Conditions and Codes of Practice (LCCP); Reg. 18, 19(1)(a) und 28(1) Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
Action
Fine
Status of proceedings
final
Sector
Other
Mitigating circumstances
A swift action plan with progress updates, full cooperation with the investigation and early acceptance of the failings.
Published
23 Jul 2026

Original amount 4,750,000 GBP, converted at the ECB reference rate of 23 Jul 2026.

Checked against the official source on 3 Oct 2026 · Direct link

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23 Jul 2026 Caisse populaire acadienne ltéeFINTRAC: CAD 676,500 penalty on Caisse populaire acadienne ltée for 3 violations of anti-money laundering obligations CanadaSuspicious activity reports €421,916

According to FINTRAC, Caisse populaire acadienne ltée is a federally regulated credit union based in Caraquet, New Brunswick. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 676,500 on the company on 23 July 2026. According to FINTRAC's findings, made during a compliance examination, the company committed 3 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, written compliance policies and procedures and assessing and documenting money laundering and terrorist financing risks. Specifically, according to FINTRAC, the credit union failed in four instances to report multiple transactions that showed indicators of suspicion. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Caisse populaire acadienne ltée", published 24 September 2026, https://fintrac-canafe.canada.ca/pen/amps/pen-2026-09-24-4-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9.6(1); PCMLTF Regulations 156(1)(b), 156(1)(c), 156(2); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
24 Sep 2026

Original amount 676,500 CAD, converted at the ECB reference rate of 23 Jul 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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23 Jul 2026 Nova Scotia Gaming CorporationFINTRAC: 231,826 CAD against Nova Scotia Gaming over missing suspicious transaction reports CanadaSuspicious activity reports €144,584

The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) imposed 231,826 CAD on the Halifax gaming corporation (casino sector) because it failed to file suspicious transaction reports on attempted transactions despite reasonable grounds for suspicion, did not keep its compliance policies up to date and approved by a senior officer, and did not assess the money laundering risk as required. The penalty was paid in full.

What organisations can take from it

Even aborted or merely attempted transactions can be reportable – cashier staff must know this.

Relevance to training and awareness

Suspicious transaction reports even for merely attempted transactions

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Proceeds of Crime (Money Laundering) and Terrorist Financing Act, Part 1, und zugehörige Verordnungen
Action
Fine
Status of proceedings
final
Sector
Other
Published
3 Sep 2026

Original amount 231,826 CAD, converted at the ECB reference rate of 23 Jul 2026.

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

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14 Jul 2026 Goldwin LtdMalta: 80,907 EUR against online casino Goldwin for missing customer risk assessment MaltaCustomer due diligence €80,907

The 2022 examination revealed that for more than two years the remote gaming operator had had no proper customer risk assessment for almost its entire player base; the assessments submitted had been prepared specifically for the examination. In addition, once players reached the deposit threshold of 2,000 EUR, it did not check in good time whether they were politically exposed persons. The Financial Intelligence Analysis Unit (FIAU) imposed 80,907 EUR; the fine was still open to appeal at the time of publication.

What organisations can take from it

Supervisory authorities see through risk assessments prepared only for the examination – they must be applied in day-to-day business.

Relevance to training and awareness

Risk-based customer assessment in gambling

Authority / court
Financial Intelligence Analysis Unit (FIAU)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Reg. 5(5)(a)(ii), 11(5), 21 PMLFTR; FIAU Implementing Procedures Part I und II (Remote Gaming)
Action
Fine
Status of proceedings
unknown
Sector
Other
Published
16 Jul 2026

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

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10 Jul 2026 Volksbank Düsseldorf Neuss eGBaFin: 210,000 EUR against Volksbank Düsseldorf Neuss over monitoring and reporting gaps GermanyCustomer due diligence €210,000

Germany's Federal Financial Supervisory Authority (BaFin) imposed fines totalling 210,000 EUR on the cooperative bank: business relationships were not monitored on an ongoing basis or with enhanced scrutiny, additional information was not obtained and suspicious activity reports were not filed or were filed late. The function of the money laundering reporting officer had been outsourced to an external service provider with several clients.

What organisations can take from it

Institutions that outsource the anti-money laundering function remain responsible themselves for ongoing monitoring and timely suspicious activity reports.

Relevance to training and awareness

Ongoing monitoring of business relationships and suspicious activity reporting

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 56 Abs. 1 S. 1 Nr. 20, 36, 38 und 69 GwG; Bekanntmachung nach § 57 GwG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
17 Sep 2026

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

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23 Jun 2026 Banca Popolare Commerciale SpaBanca d'Italia: 40,000 EUR against Banca Popolare Commerciale over AML deficiencies ItalyCustomer due diligence €40,000

Following an on-site inspection from February to April 2025, the Bank of Italy (Banca d'Italia) found deficiencies in customer due diligence, active cooperation (suspicious transaction reporting) and anti-money laundering controls, and imposed an administrative fine of 40,000 EUR. The duration of the deficiencies and the corrective measures initiated were taken into account.

What organisations can take from it

Gaps in customer due diligence and suspicious transaction reporting are consistently sanctioned after on-site inspections, even with smaller amounts – corrective measures reduce the sanction but do not replace it.

Relevance to training and awareness

Customer due diligence and suspicious transaction reports

Authority / court
Banca d'Italia
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 62 d.lgs. 231/2007; Verstöße gegen Art. 7, 16–19, 24, 25, 35, 36 d.lgs. 231/2007
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Corrective measures initiated

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

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19 Jun 2026 CACEIS Bank (UK Branch)FCA: public censure for CACEIS UK over deficient checks on a custody client United KingdomCustomer due diligence Reprimand or warning

The UK Financial Conduct Authority (FCA) issued a public censure because the London branch opened and operated accounts for the wealth manager WealthTek, although its own register searches showed that it lacked permissions to hold client assets, and overlooked a restriction noted in the register; 16 monitoring alerts were not worked through over two years, and more than £314 million flowed through the accounts. In view of cooperation and a voluntary payment of £31.7 million to WealthTek clients, the FCA refrained from imposing a fine (otherwise £23.1 million after discount).

What organisations can take from it

Anyone who notices a discrepancy in the register must clarify and document it before accounts are activated.

Relevance to training and awareness

Register checks and follow-up on identified KYC gaps

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Section 205 FSMA (Public Censure) wegen Verstoßes gegen FCA Principle 2; Maßstab u. a. SYSC 6.1.1R, 6.3.1R, 6.3.3R und Regulations 18, 27, 28 MLR 2017
Action
Reprimand or warning
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Cooperation, acknowledgement of the deficiencies and a voluntary payment of £31,714,068 to those harmed
Published
25 Jun 2026
Sources

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

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17 Jun 2026 Ikano Bank ABIkano Bank: 140 million SEK over deficiencies in money laundering risk assessment and customer due diligence SwedenCustomer due diligence €12.9m

For the period April 2022 to May 2023, the Swedish financial supervisory authority Finansinspektionen (FI) found that the bank’s general risk assessment did not realistically assess the terrorist financing risks of its corporate products and that no enhanced due diligence measures were taken for high-risk corporate customers. FI issued a remark and imposed 140 million SEK; the bank has brought an action before the administrative court.

What organisations can take from it

The money laundering risk assessment must reflect the actual customers and products – a generic assessment leaves the entire customer due diligence open to challenge.

Relevance to training and awareness

Enhanced due diligence for high-risk customers

Authority / court
Finansinspektionen (FI)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Penningtvättslagen (2017:630)
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
17 Jun 2026

Original amount 140,000,000 SEK, converted at the ECB reference rate of 17 Jun 2026.

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

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17 Jun 2026 MX Global Ltd (MEXC)VARA fines MX Global (MEXC) for unlicensed crypto services and missing KYC United Arab EmiratesCustomer due diligence Fine

According to investigations by the Virtual Assets Regulatory Authority (VARA, Dubai's virtual assets regulator), MX Global Ltd, which trades under the MEXC brand, provided broker-dealer and/or exchange services to customers in Dubai without a licence from 2022 to April 2026 and onboarded users without the KYC checks required by law. VARA imposed fines of an undisclosed amount and ordered the immediate cessation of all unlicensed activities in or from Dubai; other group companies were expressly not affected.

What organisations can take from it

Serving customers in a market requires a licence there – and local KYC obligations must be met regardless.

Relevance to training and awareness

Licensing requirement and KYC for cross-border crypto services

Authority / court
Virtual Assets Regulatory Authority (VARA), Dubai
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Federal Decree-Law No. (10) of 2025 (AML/CFT/PF); Dubai Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai; Cabinet Resolution No. 111/2022; VARA Regulations and Rulebooks
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Full cooperation, compliance with the cease-and-desist orders and a stated intention to apply for a VARA licence.
Published
22 Jun 2026

Checked against the official source on 3 Oct 2026 · Direct link

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5 Jun 2026 Caisse populaire Alliance limitéeFINTRAC: CAD 82,500 penalty on Caisse populaire Alliance limitée for 4 violations of anti-money laundering obligations CanadaCustomer due diligence €51,055

According to FINTRAC, Caisse populaire Alliance limitée is a provincially regulated credit union based in North Bay, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 82,500 on the company on 5 June 2026. According to FINTRAC's findings, made during a compliance examination, the company committed 4 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, enhanced measures for high-risk situations, assessing and documenting money laundering and terrorist financing risks and the prescribed review of the compliance programme. Specifically, according to FINTRAC, 46 of 118 high-risk clients were not reviewed annually, contrary to the credit union's own policies. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Caisse populaire Alliance limitée", published 24 September 2026, https://fintrac-canafe.canada.ca/pen/amps/pen-2026-09-24-1-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
PCMLTFA s. 9.6(1), 9.6(3); PCMLTF Regulations 156(1)(b), 156(1)(c), 156(1)(f), 156(2), 156(3), 157; Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
24 Sep 2026

Original amount 82,500 CAD, converted at the ECB reference rate of 5 Jun 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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4 Jun 2026 Pathwise Credit UnionFINTRAC: CAD 41,250 penalty on Pathwise Credit Union for 2 violations of anti-money laundering obligations CanadaInternal controls €25,501

According to FINTRAC, Pathwise Credit Union is a provincially regulated credit union based in Oshawa, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 41,250 on the company on 4 June 2026. According to FINTRAC's findings, made during a compliance examination, the company committed 2 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures and assessing and documenting money laundering and terrorist financing risks. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Pathwise Credit Union", published 24 September 2026, https://fintrac-canafe.canada.ca/pen/amps/pen-2026-09-24-3-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 9.6(1); PCMLTF Regulations 156(1)(b), 156(1)(c); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
24 Sep 2026

Original amount 41,250 CAD, converted at the ECB reference rate of 4 Jun 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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3 Jun 2026 CoinMENA FZEVARA fines CoinMENA over failings in its anti-money laundering programme United Arab EmiratesInternal controls Fine

The Virtual Assets Regulatory Authority (VARA, Dubai's virtual assets regulator) had licensed CoinMENA FZE to provide broker-dealer services on 30 November 2023. In ongoing supervisory inspections covering its entire market operations from the outset up to and including the 2025 financial year, VARA found administrative weaknesses in internal systems and controls that led to compliance failures in the company's anti-money laundering programme. VARA imposed a fine, the amount of which was not published.

What organisations can take from it

Even a licensed provider must keep its anti-money laundering programme aligned with its actual operations – the regulator reviews the entire period of operation.

Relevance to training and awareness

Internal controls in the AML programmes of crypto service providers

Authority / court
Virtual Assets Regulatory Authority (VARA), Dubai
Area of law
Money laundering and terrorist financing · Internal controls
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Full cooperation, acceptance of the findings and a coordinated remediation plan.
Published
22 Jun 2026

Checked against the official source on 3 Oct 2026 · Direct link

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2 Jun 2026 Euro Exchange Securities UK LtdFCA halts e-money institution Euro Exchange Securities UK over money laundering risks United KingdomInternal controls Order

The FCA barred the e-money institution Euro Exchange Securities UK Ltd with immediate effect from providing any e-money and payment services, prohibited any dealing with customer funds without its consent and required an independent third party to oversee their return. According to the FCA, the reasons were systemic weaknesses in combating financial crime – in customer risk assessment, customer due diligence and enhanced due diligence, screening, transaction monitoring and governance – together with indications that the obligations to safeguard customer funds were not being met. On the FCA's application the court appointed interim managers on 4 June 2026 and confirmed the special administration on 11 June 2026.

What organisations can take from it

Payment institutions must be able to evidence customer due diligence, transaction monitoring and the segregation of customer funds at all times, or face immediate shutdown.

Relevance to training and awareness

Anti-money laundering and safeguarding of customer funds at payment service providers

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
reg. 11(1) Electronic Money Regulations 2011 i. V. m. regs. 6(5)(b), 6(5)(c), 6(6)(d), 20 und 37 EMRs; Money Laundering Regulations 2017
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Published
5 Jun 2026

Checked against the official source on 3 Oct 2026 · Direct link

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29 May 2026 Atlantic Lottery Corporation Inc.FINTRAC: CAD 212,025 penalty on Atlantic Lottery Corporation Inc. for 3 violations of anti-money laundering obligations CanadaSuspicious activity reports €131,906

According to FINTRAC, Atlantic Lottery Corporation Inc. is a reporting entity in the casino sector based in Moncton, New Brunswick. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 212,025 on the company on 29 May 2026. According to FINTRAC's findings, made during a compliance examination, the company committed 3 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, written compliance policies and procedures and assessing and documenting money laundering and terrorist financing risks. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Atlantic Lottery Corporation Inc.", published 9 July 2026, https://fintrac-canafe.canada.ca/pen/amps/pen-2026-07-09-1-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9.6(1); PCMLTF Regulations 156(1)(b), 156(1)(c); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Other
Published
9 Jul 2026

Original amount 212,025 CAD, converted at the ECB reference rate of 29 May 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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25 May 2026 Padang Trust Singapore Pte. Ltd.MAS: SGD 300,000 against Padang Trust over failures in suspicious transaction reporting SingaporeSuspicious activity reports €201,708

The Monetary Authority of Singapore (MAS, Singapore's central bank and financial regulator) allegedly imposed a composition penalty of SGD 300,000 on the licensed trust company Padang Trust Singapore Pte. Ltd. because it failed to inquire into unusual transactions with no apparent economic or lawful purpose and did not file suspicious transaction reports promptly. According to MAS, the causes were inadequate controls, including a lack of scrutiny of unusual transactions and low staff awareness of money laundering and terrorist financing risks and red flags; the company paid the penalty, took remedial action and appointed an independent reviewer to confirm that the measures are effective. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Failing to question unusual transactions and delaying suspicious transaction reports breaches core anti-money laundering duties – staff must know the typical red flags.

Relevance to training and awareness

Recognising unusual transactions and filing suspicious transaction reports without delay

Authority / court
Monetary Authority of Singapore (MAS)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
MAS Notice TCA-N03; s 27B(2) Monetary Authority of Singapore Act (Cap. 186); Composition nach s 176(1A) MAS Act 1970
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
25 May 2026

Original amount 300,000 SGD, converted at the ECB reference rate of 25 May 2026.

Checked against the official source on 4 Oct 2026 · Direct link

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11 May 2026 Banco Topázio S.A.Banco Topázio: BRL 16.28m and crypto FX ban over anti-money laundering failings BrazilSuspicious activity reports €2.82m

The sanctions committee COPAS of the Banco Central do Brasil (central bank) imposed fines totalling BRL 16,280,000.00 on Banco Topázio S.A.: BRL 4,560,000.00 because its monitoring system contained no rules for foreign exchange transactions to buy and sell virtual assets, BRL 3,280,000.00 because suspicious transactions were not reported, or reported late, to the financial intelligence unit Coaf (including BRL 3.05bn from one client), and BRL 8,440,000.00 because the bank had not verified the qualification of foreign exchange clients. In addition, for two years it may not carry out over-the-counter foreign exchange transactions for virtual assets in which the client acts as an unauthorised intermediary for third parties. The decision is not final.

What organisations can take from it

Anyone processing foreign exchange for crypto intermediaries needs suitable monitoring scenarios and must also know the customers behind the customers.

Relevance to training and awareness

Anti-money laundering monitoring of foreign exchange with crypto intermediaries

Authority / court
Banco Central do Brasil (Comitê de Decisão de Processo Administrativo Sancionador – COPAS)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Lei 9.613/1998, Art. 10 III, Art. 11 II, Art. 12 II und § 2 II und IV; Circular BCB 3.978/2020, Arts. 38, 39 und 48; Lei 13.506/2017, Art. 3 XVII, Art. 5 II und IV
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.

Original amount 16,280,000 BRL, converted at the ECB reference rate of 11 May 2026.

Checked against the official source on 3 Oct 2026 · Direct link

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6 May 2026 Československá obchodní banka, a. s.ČNB: CZK 30m fine for ČSOB over customer due diligence and AML control failures CzechiaCustomer due diligence €1.23m

The Česká národní banka (ČNB, Czech National Bank) fined Československá obchodní banka 30,000,000 CZK under the Czech anti-money laundering act. For customers internally rated as high-risk, including a credit institution, the bank did not adequately examine the purpose and background of transactions such as 58 cash withdrawals and did not fully screen ownership and management structures against sanctions lists. It also lacked effective internal procedures for ongoing customer due diligence and for enhanced due diligence on transactions involving high-risk third countries; for 8,414 legal entities with complex structures, the whole structure was not screened for sanctions.

What organisations can take from it

High-risk customers, especially other financial institutions, need ongoing, documented review of their transactions and of their entire ownership chain, including sanctions screening.

Relevance to training and awareness

Customer due diligence and transaction monitoring for high-risk customers

Authority / court
Česká národní banka (ČNB)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 9 Abs. 1 lit. c, § 9a Abs. 1, § 21 Abs. 1, § 44 Abs. 1 lit. b und Abs. 3 lit. d, § 48 Abs. 1 Zákon č. 253/2008 Sb. (AML-Gesetz)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 30,000,000 CZK, converted at the ECB reference rate of 6 May 2026.

Checked against the official source on 28 Sep 2026 · Direct link

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24 Apr 2026 Anwaltskanzlei aus Hamilton (anonymisiert)Hamilton law firm: 60,000 NZD fine for anti-money laundering breaches New ZealandInternal controls €30,092

Between March 2022 and March 2025 a Hamilton law firm repeatedly breached the AML/CFT Act: it lacked a proper risk assessment, an implemented anti-money laundering programme and adequate records. It also failed to respond, or responded only in part, to information notices from the Department of Internal Affairs (DIA, the AML/CFT supervisor for law firms), thereby obstructing its investigators. After the firm pleaded guilty, the court imposed a fine of 60,000 NZD, taking the firm's size and financial capacity into account.

What organisations can take from it

Even small law firms must actually implement their risk assessment, AML programme and record keeping and answer supervisory information requests in full.

Relevance to training and awareness

Anti-money laundering duties in law firms and cooperation with the supervisor

Authority / court
Strafgericht, in der Quelle nicht benannt (Anklage: Department of Internal Affairs)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Anti-Money Laundering and Countering Financing of Terrorism Act 2009
Action
Fine
Status of proceedings
unknown
Sector
Other
Culpability
intentional
Liability of senior managers
According to the Department of Internal Affairs, the firm's partners, as lawyers, also had professional obligations to uphold the law.
Published
24 Apr 2026

Original amount 60,000 NZD, converted at the ECB reference rate of 24 Apr 2026.

Checked against the official source on 3 Oct 2026 · Direct link

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27 Mar 2026 13010431 Canada Inc. (Necosmart)FINTRAC: 693,742 CAD against crypto service provider Necosmart over missing suspicious transaction reports CanadaSuspicious activity reports €434,295

The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) imposed 693,742.50 CAD on the Edmonton money services business, which also exchanges virtual currencies, for five violations: repeated failure to file suspicious transaction reports, lack of written compliance policies, insufficient enhanced measures for high-risk transactions, lack of a risk assessment and incomplete records of occupation and transactions for crypto exchanges.

What organisations can take from it

Small crypto exchange offices need the same basic framework as banks: risk analysis, policies, enhanced scrutiny and reporting.

Relevance to training and awareness

Recognising and reporting grounds for suspicion in crypto exchange

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Proceeds of Crime (Money Laundering) and Terrorist Financing Act, Part 1, und zugehörige Verordnungen
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
14 May 2026

Original amount 693,742.5 CAD, converted at the ECB reference rate of 27 Mar 2026.

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

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23 Mar 2026 Stanleybet Malta LimitedMalta: 225,730 EUR against betting operator Stanleybet over lack of customer checks in betting shops MaltaCustomer due diligence €225,730

Malta's Financial Intelligence Analysis Unit (FIAU) imposed 225,730 EUR, a penalty payment of 2,000 EUR per day and a follow-up directive on the licensed gambling operator, which works through a network of independently operated betting shops in an EU member state. The company was unable to link customers' cumulative deposits across different shops and only checked customers from a single deposit of 2,000 EUR upwards, so the threshold could be circumvented. The company has appealed.

What organisations can take from it

Thresholds must be aggregated per customer across all channels and branches – otherwise the system invites structuring.

Relevance to training and awareness

Recognising structured deposits below the checking threshold

Authority / court
Financial Intelligence Analysis Unit (FIAU)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Regulation 21 PMLFTR; Verstöße gegen Regulations 5(5)(a)(ii), 7, 9(1) PMLFTR und FIAU Implementing Procedures
Action
Fine
Status of proceedings
under appeal
Sector
Other
Published
16 Apr 2026
Sources

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

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17 Mar 2026 Bithumb Co., Ltd.Bithumb: partial suspension and KRW 36.9bn fine for anti-money laundering breaches South KoreaCustomer due diligence €21.5m

The KoFIU (Korea Financial Intelligence Unit) found that the crypto exchange Bithumb had processed 45,772 transfers of crypto assets with 18 virtual asset service providers that had not complied with their reporting obligation between August 2022 and April 2025, and had breached customer identification duties and the associated transaction restrictions in large numbers; there were also shortcomings in suspicious transaction reporting, record keeping and the risk assessment of new products. On 17 March 2026 it ordered a six-month partial suspension of business (no transfers of crypto assets for new customers from 27 March to 26 September 2026) and imposed a fine of KRW 36,873.5 million. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Crypto exchanges must check counterparties for deposits and withdrawals against the register of reported providers before allowing transfers.

Relevance to training and awareness

Counterparty checks and customer identification for crypto transfers

Authority / court
Korea Financial Intelligence Unit (KoFIU)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 4, 5, 5-2, 5-4 und 8 Act on Reporting and Using Specified Financial Transaction Information; Art. 9, 10-6, 10-9 und 10-20 Durchführungsverordnung (Teilsperre wegen Art. 8 i. V. m. Art. 10-20 DVO: Geschäfte mit nicht gemeldeten Anbietern)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
17 Mar 2026

Original amount 36,873,500,000 KRW, converted at the ECB reference rate of 17 Mar 2026.

Checked against the official source on 4 Oct 2026 · Direct link

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17 Mar 2026 Hakrinbank N.V.; Finabank N.V.; De Surinaamsche Bank N.V.OM: settlements with three Surinamese banks over negligent money laundering NetherlandsCustomer due diligence €415,000

Hakrinbank N.V., Finabank N.V. and De Surinaamsche Bank N.V. concluded transactions (out-of-court settlements) with the Openbaar Ministerie (OM, Dutch Public Prosecution Service) over suspected negligent money laundering (schuldwitwassen) in 2018 and are paying a total of 415,000 EUR (Hakrinbank 166,000 EUR, Finabank and De Surinaamsche Bank 124,500 EUR each). The trigger was the seizure at Schiphol Airport in April 2018 of 19.5 million EUR in cash belonging to the three banks and bound for Hong Kong; the OM accused them of not having adequately checked the origin of the cash in Suriname, in particular who the customers of the bureaux de change among their clients were. The OM found no intent; it took into account the age of the case and the lesser seriousness of negligent money laundering, and the seized money will be returned.

What organisations can take from it

Banks that accept cash from bureaux de change and ship it internationally must include their customers’ customers in checks on its origin.

Relevance to training and awareness

Checking the origin of cash shipments and customers of bureaux de change

Authority / court
Openbaar Ministerie (OM), Arrondissementsparket Noord-Holland
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Schuldwitwassen (fahrlässige Geldwäsche nach niederländischem Strafrecht); Transaktion des OM
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
negligent
Mitigating circumstances
No intent established; age of the case; the banks have since implemented improvements in cash controls, KYC and governance.
Published
17 Mar 2026

Checked against the official source on 2 Oct 2026 · Direct link

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11 Mar 2026 Birks Group Inc.FINTRAC: jeweller Birks sanctioned over missing risk assessment and compliance review CanadaInternal controls €32,755

The nationwide jewellery chain (a dealer in precious metals and stones) received a penalty of 51,562.50 CAD from the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) because written compliance policies were lacking or not applied, the money laundering risk was not assessed and documented, and the prescribed two-yearly effectiveness review was not carried out. Birks has appealed to the Federal Court.

What organisations can take from it

Jewellers, too, must maintain a documented compliance programme with a risk assessment and regular effectiveness reviews.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Proceeds of Crime (Money Laundering) and Terrorist Financing Act, Part 1, und zugehörige Verordnungen
Action
Fine
Status of proceedings
under appeal
Sector
Retail and e-commerce
Published
5 May 2026

Original amount 51,562.5 CAD, converted at the ECB reference rate of 11 Mar 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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5 Mar 2026 Stonehage Fleming Luxembourg S.A.Stonehage Fleming Luxembourg: EUR 56,000 for late suspicious activity reports LuxembourgSuspicious activity reports €56,000

The CSSF fined the specialised financial services provider, whose domiciliation business was inspected, EUR 56,000 (around 2% of annual turnover). In four cases involving adverse media on possible corruption or drug trafficking, the company reported to the FIU only after the CSSF asked and incompletely; in six further cases with indications of corruption, bribery and tax offences no report was made at all.

What organisations can take from it

Adverse media on clients requires the firm's own investigation and, if suspicion remains, a complete report – not only when the supervisor asks.

Relevance to training and awareness

Investigating adverse media and reporting completely and on time

Authority / court
Commission de Surveillance du Secteur Financier (CSSF)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Art. 2-1(1) i. V. m. Art. 8-4(1), (2)(f) und (3)(a) Loi modifiée du 12 novembre 2004 (LBC/FT); verletzt u. a. Art. 5(1)(a); Règlement CSSF 12-02
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Limited scope of the inspection; findings acknowledged, action plan and remedial measures.
Published
9 Jun 2026

Checked against the official source on 2 Oct 2026 · Direct link

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3 Mar 2026 BNF Bank p.l.c.Malta: 69,000 EUR against BNF Bank over late reporting to the bank account register MaltaMoney laundering and terrorist financing €69,000

Following the introduction of a new core banking system in April 2025, the bank was unable, until September 2025, to submit the mandatory weekly data deliveries to the Centralised Bank Account Register (CBAR) on time. The Financial Intelligence Analysis Unit (FIAU) imposed 69,000 EUR.

What organisations can take from it

Test regulatory reporting chains in advance of IT migrations – migration problems do not excuse missed deadlines.

Authority / court
Financial Intelligence Analysis Unit (FIAU)
Area of law
Money laundering and terrorist financing
Legal basis
Reg. 4(2), 8 Centralised Bank Account Register Regulations (S.L. 373.03)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The bank continuously attempted to upload reports
Published
6 Mar 2026

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

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2 Mar 2026 Northern Isga FoundationFINTRAC: CAD 91,162.50 penalty on Northern Isga Foundation for 4 violations of anti-money laundering obligations CanadaInternal controls €57,009

According to FINTRAC, Northern Isga Foundation is a non-profit charitable organisation based in Glenevis, Alberta, that receives a portion of a casino's revenues and is therefore a reporting entity. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 91,162.50 on the foundation on 2 March 2026. According to FINTRAC's findings, made during a compliance examination, the foundation committed 4 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the compliance training programme and the prescribed review of the compliance programme. According to FINTRAC, the foundation has appealed the decision to the Federal Court. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Northern Isga Foundation", published 26 March 2026, https://fintrac-canafe.canada.ca/pen/amps/pen-2026-03-26-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 9.6(1); PCMLTF Regulations 156(1)(b), 156(1)(c), 156(1)(d), 156(1)(e), 156(1)(f); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Other
Published
26 Mar 2026

Original amount 91,162.5 CAD, converted at the ECB reference rate of 2 Mar 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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27 Feb 2026 MBaer Merchant Bank AGFINMA withdraws MBaer Merchant Bank's licence over serious anti-money laundering deficiencies SwitzerlandInternal controls Order

Following enforcement proceedings, the Swiss Financial Market Supervisory Authority (FINMA) found serious, systematic deficiencies in anti-money laundering due diligence, organisation and risk management; the bank enabled clients to circumvent official asset freezes and executed transactions for sanctioned persons. FINMA had withdrawn the bank's licence and ordered its liquidation; with the withdrawal of the appeal before the Federal Administrative Court, the orders took effect on 27 February 2026. The day before, FinCEN had proposed designating the bank as an institution of primary money laundering concern.

What organisations can take from it

Systematic anti-money laundering and sanctions deficiencies can cost a bank its licence – not just money.

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Schweizer Geldwäschereirecht und Bankenaufsichtsrecht (laut FINMA)
Action
Order
Status of proceedings
final
Sector
Financial services and insurance
Employees
50 to 249
Published
27 Feb 2026
Sources

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23 Feb 2026 COFIDIS SA (Zweigniederlassung Slowakei)NBS: EUR 160,000 fine for the COFIDIS branch over 23 anti-money laundering failings SlovakiaInternal controls €160,000

The NBS (National Bank of Slovakia) fined the French bank COFIDIS 160,000 EUR in respect of its Slovak branch for 23 breaches found in an on-site inspection that began in May 2021. The anti-money laundering programme was outdated and incomplete (among other things it lacked current details of the money laundering officer, clear rules on when standard and when enhanced due diligence applies, the branch's own risk assessment and record-keeping requirements); in 2020 only 5 of 27 staff were trained, and 6 of 7 newly hired staff with AML tasks were not trained within three months. The branch also failed to verify customers' identity adequately for online products and electronic signing, did not identify politically exposed persons, did not monitor third-party payments into loan accounts, did not report refusals of unusual transactions to the financial intelligence unit and submitted inaccurate customer data to the NBS.

What organisations can take from it

An AML programme must be updated every year, and new staff with AML duties need their training within the statutory deadline.

Relevance to training and awareness

AML training for existing and new staff

Missing or inadequate training played a role in the decision.

Authority / court
Národná banka Slovenska (NBS)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
§ 10, § 12, § 14, § 17, § 19, § 20 Abs. 1 bis 3, § 20a Zákon č. 297/2008 Z. z. (AML-Gesetz); § 27 Abs. 2, § 42 Abs. 2, § 50 Abs. 1 lit. d Zákon č. 483/2001 Z. z. (Bankengesetz)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Checked against the official source on 28 Sep 2026 · Direct link

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23 Feb 2026 VersaBankFINTRAC: CAD 42,075 penalty on VersaBank for 2 violations of anti-money laundering obligations CanadaCustomer due diligence €26,082

According to FINTRAC, VersaBank is a bank based in London, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 42,075 on the company on 23 February 2026. According to FINTRAC's findings, the company committed 2 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures and enhanced measures for high-risk situations. Specifically, according to FINTRAC, the bank failed in at least seven instances to correctly identify elevated or high-risk clients and apply enhanced due diligence. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on VersaBank", published 5 May 2026, https://fintrac-canafe.canada.ca/pen/amps/pen-2026-05-05-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
PCMLTFA s. 9.6(1), 9.6(3); PCMLTF Regulations 156(1)(b), 157; Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
5 May 2026

Original amount 42,075 CAD, converted at the ECB reference rate of 23 Feb 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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20 Feb 2026 BVwG reduces FMA penalty against private bank over unclarified beneficial owners AustriaCustomer due diligence €356,000

From 2017 to 2020, an Austrian bank specialising in private and investment banking had not adequately examined the ownership and control structure of an offshore holding client despite the lack of evidence on shareholders, trust arrangements and beneficial owners. The Austrian Federal Administrative Court (Bundesverwaltungsgericht, BVwG) confirmed the infringement but reduced the additional penalty imposed by the Financial Market Authority (Finanzmarktaufsicht, FMA) in its penalty decision of 17 December 2024 from 476,000 to 356,000 EUR (total penalty 436,000 EUR less FMA penalties already paid), because the FMA had taken the seriousness of the offence into account twice and the bank had cooperated, admitted its errors and terminated the client relationship; an appeal on points of law has been permitted.

What organisations can take from it

For offshore holdings with trustees, prove the beneficial owner with supporting documents – a self-declaration is not enough.

Relevance to training and awareness

Identifying beneficial owners in holding and trust structures

Authority / court
Bundesverwaltungsgericht (BVwG); Straferkenntnis der Finanzmarktaufsicht (FMA) vom 17.12.2024
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 9 Abs. 1 erster Satz i. V. m. § 6 Abs. 1 Z 2 FM-GwG; § 35 Abs. 1 und 3 i. V. m. § 34 Abs. 1 Z 2 und Abs. 2 FM-GwG; § 22 Abs. 9 FMABG (Zusatzstrafe)
Action
Fine
Status of proceedings
reduced
Sector
Financial services and insurance
Culpability
negligent
Mitigating circumstances
Reduction by the court because the wrongfulness of the offence had been counted twice, cooperation, admission of the facts and of guilt, and termination of the client relationship

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

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17 Feb 2026 BVwG upholds 588,000 EUR FMA penalty against major bank over incorrect risk classification AustriaCustomer due diligence €588,000

The Austrian Federal Administrative Court (Bundesverwaltungsgericht, BVwG) dismissed the appeal of a listed major Austrian bank and upheld the fine of 588,000 EUR (plus 58,800 EUR in procedural costs) imposed by the Financial Market Authority (Finanzmarktaufsicht, FMA) in its penalty decision of 19 November 2024. From 2017 to 2020, the bank had not adequately risk-classified three business relationships and had disregarded sector risks such as gambling and precious metals trading as well as cash intensity; an appeal on points of law has been permitted.

What organisations can take from it

Customers from gambling or precious metals trading with a high share of cash belong in a higher risk class – otherwise the enhanced obligations are missing.

Relevance to training and awareness

Risk classification of cash-intensive high-risk sectors

Authority / court
Bundesverwaltungsgericht (BVwG); Straferkenntnis der Finanzmarktaufsicht (FMA) vom 19.11.2024
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 6 Abs. 5 i. V. m. § 34 Abs. 1 Z 2 und § 35 Abs. 1–3 FM-GwG
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

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

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12 Feb 2026 Louis Vuitton BVOM: €500,000 penalty order for Louis Vuitton BV over inadequate customer checks NetherlandsCustomer due diligence €500,000

The Openbaar Ministerie (OM, Dutch Public Prosecution Service) imposed a penalty order of 500,000 EUR on the Dutch Louis Vuitton BV for breaches of the Wwft (Dutch Anti-Money Laundering and Anti-Terrorist Financing Act) because, over a long period, the company did not sufficiently check who the customers were who repeatedly spent large amounts in cash. The case arises from ongoing money laundering proceedings in which, according to the OM, a buyer spent a total of more than 2 million EUR of criminal proceeds under various names on luxury goods in shops such as those of Louis Vuitton between August 2021 and February 2023 and sent the bags to China for resale; a then sales employee allegedly helped her and warned her whenever she was about to spend more than 10,000 EUR a month through one of her customer accounts. The OM settled the matter out of court to free up scarce hearing capacity at the Rechtbank Rotterdam (Rotterdam District Court).

What organisations can take from it

Luxury retailers must spot repeated cash purchases by the same person under different names and make staff aware of attempts to circumvent reporting thresholds.

Relevance to training and awareness

Cash transactions in luxury retail, structuring and staff involvement

Authority / court
Openbaar Ministerie (OM), Landelijk Parket
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft), Kundenprüfung; Strafbefehl des OM
Action
Fine
Status of proceedings
unknown
Sector
Retail and e-commerce
Published
12 Feb 2026

Checked against the official source on 2 Oct 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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4 Feb 2026 RE/MAX Twin City Realty Inc.FINTRAC: CAD 24,750 penalty on RE/MAX Twin City Realty Inc. for one violation of anti-money laundering obligations CanadaInternal controls €15,336

According to FINTRAC, RE/MAX Twin City Realty Inc. is a real estate brokerage based in Kitchener, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 24,750 on the company on 4 February 2026. According to FINTRAC's findings, made during a compliance examination, the company committed one violation of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violation concerned assessing and documenting money laundering and terrorist financing risks. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on RE/MAX Twin City Realty Inc.", published 5 May 2026, https://fintrac-canafe.canada.ca/pen/amps/pen-2026-05-05-1-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 9.6(1); PCMLTF Regulations 156(1)(c); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Published
5 May 2026

Original amount 24,750 CAD, converted at the ECB reference rate of 4 Feb 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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28 Jan 2026 CCV Group B.V.Netherlands: payment institution CCV without integrity risk analysis – 406,125 EUR fine NetherlandsInternal controls €406,125

Until March 2018, the payment institution had no systematic integrity risk analysis (SIRA) and therefore no systematic identification and analysis of integrity risks for its gatekeeper function. The Dutch central bank (De Nederlandsche Bank, DNB) imposed the fine in 2020; following objection and appeal proceedings, it was fixed at the reduced amount of 406,125 EUR by the decision of 28 January 2026 and was published in July 2026.

What organisations can take from it

Without a documented integrity risk analysis, any money laundering prevention lacks its foundation – and that alone is subject to fines.

Authority / court
De Nederlandsche Bank (DNB)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 3:10 Wet op het financieel toezicht (Wft); Art. 10 Besluit prudentiële regels Wft (Bpr)
Action
Fine
Status of proceedings
reduced
Sector
Financial services and insurance
Mitigating circumstances
Fine reduced in the objection and appeal proceedings
Published
21 Jul 2026
Sources

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

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22 Jan 2026 Saxo Bank A/SSaxo Bank: DKK 313m for deficient customer due diligence on white-label clients DenmarkCustomer due diligence €41.9m

Saxo Bank accepted an administrative fine of 313,000,000 DKK from the Finanstilsynet (Danish Financial Supervisory Authority). For a number of customer relationships the bank had not obtained sufficient information on the purpose and intended nature of the business relationship, and between January 2021 and May 2023 it did not carry out ongoing monitoring of the end customers of its white-label partners, to whom it provided its trading platform. The fine was reduced because of the bank's cooperation in the investigation and the remedial steps taken, and in view of the bank's financial solidity.

What organisations can take from it

Anyone who opens their platform to partners for the partners' customers must include those end customers in ongoing anti-money-laundering monitoring.

Relevance to training and awareness

Customer due diligence and ongoing monitoring in white-label and partner models

Authority / court
Finanstilsynet
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Hvidvaskloven § 11 stk. 1 nr. 4 og 5; administratives Bußgeld nach § 78 a hvidvaskloven
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Cooperation in the investigation and remedial action on collecting the purpose and nature of the business relationship; reduction in view of the bank's financial solidity.
Published
23 Jan 2026

Original amount 313,000,000 DKK, converted at the ECB reference rate of 22 Jan 2026.

Checked against the official source on 28 Sep 2026 · Direct link

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20 Jan 2026 Cardif Lux Vie S.A.Cardif Lux Vie: 615,000 EUR over deficiencies in money laundering questionnaires and customer files LuxembourgCustomer due diligence €615,000

An on-site inspection in 2023 revealed that the life insurer in some cases did not handle the mandatory money laundering risk assessment questionnaires in compliance with the rules, that the employees responsible lacked sufficiently precise instructions and that customer files contained many incorrect answers. The Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) imposed 615,000 EUR.

What organisations can take from it

Risk questionnaires are only as good as the guidance given to those who complete them – clear work instructions and training are part of this.

Relevance to training and awareness

Money laundering risk assessment by employees

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Loi modifiée du 12 novembre 2004 (LBC/FT), Art. 2-1, 8-4, 8-5; Règlement CAA 20/03
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Close cooperation with the CAA during and after the inspection; remediation plan for all deficiencies submitted promptly.
Published
1 Jul 2026

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

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12 Jan 2026 Trident Trust Company (Cyprus) LimitedTrustee services firm Trident Trust Cyprus pays EUR 70,000 in money laundering settlement CyprusInternal controls €70,000

CySEC (Cyprus Securities and Exchange Commission) reached a settlement with the administrative services provider (ASP) over possible breaches of the money laundering law and the CySEC anti-money laundering directive in the period 2015–2020. It covered adequate policies, controls and procedures, risk identification, the board's responsibilities and the compliance officer's duties; the company allegedly paid EUR 70,000. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

With trust and corporate service providers, the regulator specifically checks whether the board and compliance officer genuinely fulfil their AML roles.

Relevance to training and awareness

Money laundering risk management at trust and company service providers

Authority / court
Cyprus Securities and Exchange Commission (CySEC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 58(a)–(d), 58A(1) Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2007; Ziff. 5(d), 9(1)(d) CySEC-Richtlinie; Vergleich nach Art. 37(4) Cyprus Securities and Exchange Commission Law of 2009
Action
Other
Status of proceedings
final
Sector
Financial services and insurance
Liability of senior managers
The settlement expressly covered the board's duties and the compliance officer's tasks under the anti-money laundering directive.
Published
6 Feb 2026

Checked against the official source on 4 Oct 2026 · Direct link

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17 Dec 2025 Payward MENA Holdings LimitedADGM: allegedly 36,000 USD fine for Payward MENA Holdings over five years of late AML returns United Arab EmiratesInternal controls €30,711

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the operator of a multilateral trading facility, which also held a custody permission, allegedly 36,000 USD because it did not file its annual AML returns for 2020 to 2024 until 16 December 2025 despite numerous reminders and did not pay the late filing fees of 2,000 USD in total. The regulator also found inadequate systems and controls; in correspondence the firm pointed to internal issues and to the departure of the user registered for the reporting portal. Without the 20% discount for early settlement the fine would have been 45,000 USD.

What organisations can take from it

Regulatory returns need clear ownership and portal access that survives staff changes.

Relevance to training and awareness

Timely regulatory returns to the supervisor

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Section 232 Financial Services and Markets Regulations 2015 (FSMR); AML Rule 4.6.1; GEN Rule 2.2.3 (Principle 3); FEES Rule 1.2.7
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Full cooperation, remediation, no previous non-compliance, limited scale of business with few clients and no customer loss identified (10% reduction); 20% discount for early settlement.

Original amount 36,000 USD, converted at the ECB reference rate of 17 Dec 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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17 Dec 2025 BeAccount Ltd (Handelsname Payine)FCA bars e-money institution BeAccount from business over customer due diligence failings United KingdomCustomer due diligence Order

The FCA barred BeAccount Ltd (trading as Payine), an authorised e-money institution, with immediate effect from all e-money and payment services, including taking on new customers and new customer funds, and required it to return customer funds and to inform customers and the public. After reviewing client files, the FCA had serious concerns that the institution was not complying with the money laundering rules – on risk assessment, internal policies, customer due diligence and enhanced due diligence for politically exposed persons – and was not managing its risks effectively.

What organisations can take from it

Customer risk ratings must be maintained transparently and reviewed regularly; treating high-risk customers as low risk puts the authorisation at stake.

Relevance to training and awareness

Customer due diligence and customer risk rating

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
reg. 11(1) Electronic Money Regulations 2011; Money Laundering Regulations 2017 (regs. 18, 19, 27, 28 und 35)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance

Checked against the official source on 3 Oct 2026 · Direct link

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16 Dec 2025 Svea Bank ABSvea Bank: SEK 170m for failings in AML risk assessment and customer due diligence SwedenCustomer due diligence €15.5m

Finansinspektionen (FI, Swedish Financial Supervisory Authority) issued Svea Bank a remark (anmärkning) and an administrative fine of 170,000,000 SEK. In the review period from 30 April 2022 to 1 May 2023 (business with legal entities), the general risk assessments were incomplete, customers were not risk-assessed as required, beneficial owners were not sufficiently identified, and enhanced due diligence on high-risk customers was omitted, insufficient or late in a large proportion of the cases reviewed. An earlier FI sanction of June 2022 for credit assessment failings was treated as only a minor aggravating factor because it concerned different obligations.

What organisations can take from it

The general money laundering risk assessment must cover every product and feed into customer risk assessment, otherwise all downstream due diligence measures are ineffective.

Relevance to training and awareness

Risk-based customer due diligence, identification of beneficial owners and enhanced due diligence for high-risk customers

Authority / court
Finansinspektionen (FI)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Lag (2017:630) om åtgärder mot penningtvätt och finansiering av terrorism, u. a. 2 kap. 1–3 §§, 3 kap. 12 och 16 §§; 15 kap. 1 och 7 §§ lagen (2004:297) om bank- och finansieringsrörelse
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
The bank pointed to its cooperation and remediation; FI did not treat this as mitigating. No damage was known to FI; in an overall assessment FI did not classify the breaches as serious and therefore refrained from a warning or licence revocation.
Published
17 Dec 2025

Original amount 170,000,000 SEK, converted at the ECB reference rate of 16 Dec 2025.

Checked against the official source on 28 Sep 2026 · Direct link

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16 Dec 2025 Hardeck Möbel GmbH & Co. KGFurniture retailer Hardeck: 379,503 EUR fine for breach of AML due diligence obligations GermanyCustomer due diligence €379,504

The Arnsberg regional government (Bezirksregierung Arnsberg), as anti-money laundering supervisor for the non-financial sector, imposed a fine of 379,503.50 EUR, final since 16 December 2025, on the furniture retailer as a dealer in goods for breach of due diligence obligations under the German Money Laundering Act (Geldwäschegesetz, GwG).

What organisations can take from it

Furniture retailers, as dealers in goods, are also obliged entities under the GwG – breaches of due diligence obligations can trigger six-figure fines.

Relevance to training and awareness

Identification for cash payments in the trade in goods

Authority / court
Bezirksregierung Arnsberg (Geldwäscheaufsicht Nichtfinanzsektor)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Geldwäschegesetz (Sorgfaltspflichten); Bekanntmachung nach § 57 GwG
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Liability of senior managers
Measures against individuals are not reported here.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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12 Dec 2025 Treuhandgesellschaft (anonymisiert)Liechtenstein: CHF 58,000 fine on trust company (due diligence, conflicts of interest) LiechtensteinCustomer due diligence €62,145

The Finanzmarktaufsicht (FMA, Liechtenstein Financial Market Authority) fined an unnamed legal person CHF 58,000 because it had not established or updated the business relationship profile as required (Sorgfaltspflichtgesetz, Due Diligence Act) and had breached the provisions of the Treuhändergesetz (Trustees Act) on conflicts of interest. These provisions require trustees and trust companies to keep their own assets strictly separate from client money, not to engage in proprietary transactions, and to disclose and document conflicts of interest towards clients; the FMA does not state which of these obligations was breached.

What organisations can take from it

Trust companies must keep client profiles up to date and systematically identify, document and disclose conflicts of interest.

Relevance to training and awareness

Business profiles and handling conflicts of interest in the trust business

Authority / court
Finanzmarktaufsicht Liechtenstein (FMA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 31 Abs. 1 Bst. e i.V.m. Art. 31 Abs. 5 Sorgfaltspflichtgesetz (SPG); Art. 81 Abs. 1 Bst. f i.V.m. Art. 81 Abs. 6 Treuhändergesetz (TrHG)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Liability of senior managers
For the Due Diligence Act breach, the fine is based on Art. 31(5) SPG, which makes the legal person liable for offences committed by persons in management positions.

Original amount 58,000 CHF, converted at the ECB reference rate of 12 Dec 2025.

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11 Dec 2025 Nationwide Building SocietyFCA: £44 million against Nationwide over financial crime controls United KingdomCustomer due diligence €50.4m

The UK Financial Conduct Authority (FCA) imposed £44,078,500 (after a 30% discount) because, from October 2016 to July 2021, the building society had no effective systems to keep due diligence and risk assessments for personal customers up to date, and did not identify personal accounts used for business purposes. As a result, one customer received 24 fraudulent Covid furlough payments totalling £27.3 million.

What organisations can take from it

Keep customer profiles continuously up to date – anyone who postpones known weaknesses for years ends up paying for the abuse.

Relevance to training and awareness

Identifying personal accounts used for business purposes

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
FCA Principle 3; SYSC 6.1.1R und 6.3.1R
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
30% settlement discount
Published
12 Dec 2025

Original amount 44,078,500 GBP, converted at the ECB reference rate of 11 Dec 2025.

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10 Dec 2025 Century 21 Heritage Group Ltd.FINTRAC: CAD 148,912.50 penalty on Century 21 Heritage Group Ltd. for one violation of anti-money laundering obligations CanadaSuspicious activity reports €92,446

According to FINTRAC, Century 21 Heritage Group Ltd. is a real estate brokerage. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 148,912.50 on the company on 10 December 2025. According to FINTRAC's findings, made during a compliance examination, the company committed one violation of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violation concerned suspicious transaction reporting. According to FINTRAC, the company has appealed the decision to the Federal Court. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Century 21 Heritage Group Ltd.", published 10 February 2026, https://fintrac-canafe.canada.ca/pen/amps/pen-2026-02-10-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7; Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Construction and real estate
Published
10 Feb 2026

Original amount 148,912.5 CAD, converted at the ECB reference rate of 10 Dec 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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9 Dec 2025 Dunamu Inc.Upbit operator Dunamu: KRW 35.2bn fine for customer due diligence failures South KoreaCustomer due diligence €20.6m

The KoFIU (Korea Financial Intelligence Unit) found that Dunamu, operator of the crypto exchange Upbit, had failed to identify customers with due care in 5,324,165 cases between October 2021 and October 2024, for instance where identity documents could not be verified, were mere copies or photos, or where addresses were blank or implausible, and had nevertheless allowed transactions in 3,331,570 of these cases. In addition, it failed to file suspicious transaction reports on 15 customers linked to warrant applications by investigative authorities, and its monitoring system did not detect unusual patterns such as large crypto deposits followed by sale and withdrawal; KoFIU imposed a fine of KRW 35,215.6 million on 9 December 2025. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Digital onboarding processes need checks that reliably reject copies of identity documents and implausible addresses before trading is possible.

Relevance to training and awareness

Customer identification (KYC) at crypto exchanges

Authority / court
Korea Financial Intelligence Unit (KoFIU)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 4, 5, 5-2 und 8 Act on Reporting and Using Specified Financial Transaction Information; Art. 9, 10-4, 10-6 und 10-20 Durchführungsverordnung
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
9 Dec 2025

Original amount 35,215,600,000 KRW, converted at the ECB reference rate of 9 Dec 2025.

Checked against the official source on 4 Oct 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 USAInternal controls €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.

What organisations can take from it

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.

Relevance to training and awareness

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.

Checked against the official source on 3 Oct 2026 · Direct link

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5 Dec 2025 Banco Santander, S.A.Paris prosecutor: Banco Santander pays €22.5m over money laundering at a Paris branch FranceMoney laundering and terrorist financing €22.5m

Banco Santander undertook to pay a public interest fine of 22,500,000 EUR in a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement) with the Paris public prosecutor. The investigation, triggered by a complaint from the bank itself, uncovered an illegal clearing system at a Paris branch: company cheques were paid into private clients' accounts and cash was handed out outside the banking system, with credits of around 49 million EUR between 2003 and 2010. The agreement was validated on 5 December 2025.

What organisations can take from it

Branches need transaction monitoring that immediately flags company cheques paid into private accounts and unusual cash withdrawals.

Relevance to training and awareness

Detecting suspicious cheque and cash flows at branches

Authority / court
Parquet de Paris (Procureure de la République, JIRS); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
Area of law
Money laundering and terrorist financing
Legal basis
Art. 41-1-2, 180-2 Code de procédure pénale (blanchiment aggravé)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
5 Dec 2025

Checked against the official source on 2 Oct 2026 · Direct link

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1 Dec 2025 VIP Realty Inc.FINTRAC: CAD 33,000 penalty on VIP Realty Inc. for one violation of anti-money laundering obligations CanadaInternal controls €20,296

According to FINTRAC, VIP Realty Inc. is a real estate brokerage based in Ottawa, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 33,000 on the company on 1 December 2025. According to FINTRAC's findings, made during a compliance examination, the company committed one violation of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violation concerned the prescribed review of the compliance programme. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on VIP Realty Inc.", published 9 July 2026, https://fintrac-canafe.canada.ca/pen/amps/pen-2026-07-09-2-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 9.6(1); PCMLTF Regulations 156(1)(f); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Published
9 Jul 2026

Original amount 33,000 CAD, converted at the ECB reference rate of 1 Dec 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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28 Nov 2025 Institute of Certified BookkeepersFCA: Public censure for Institute of Certified Bookkeepers over deficient AML supervision United KingdomMoney laundering and terrorist financing Reprimand or warning

The FCA, through its supervisor OPBAS, publicly censured the Institute of Certified Bookkeepers. The professional body is responsible for anti-money laundering supervision of more than 3,000 bookkeepers in the UK. The FCA found that between January 2022 and July 2023 it did not supervise its members effectively or on a risk basis; among other things it suspended inspections for more than nine months and did not keep adequate records of its supervision.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing
Legal basis
Regulation 16 Oversight of Professional Body AML and CTF Supervision Regulations 2017; Regulations 17 und 46 MLRs 2017
Action
Reprimand or warning
Status of proceedings
final
Sector
Other

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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27 Nov 2025 Manor Windsor Realty Ltd.FINTRAC: estate agent Manor Windsor Realty without AML training programme – 107,250 CAD CanadaInternal controls €65,907

The estate agency in Windsor (Ontario) received a penalty of 107,250 CAD from the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) for four violations: no up-to-date, approved compliance policies, no assessment of the money laundering risk, no written ongoing training programme and no effectiveness review of the compliance programme. The company has appealed to the Federal Court.

What organisations can take from it

For estate agents, a missing written training programme is a separate violation subject to penalties.

Relevance to training and awareness

AML training programme for estate agents

Missing or inadequate training played a role in the decision.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Proceeds of Crime (Money Laundering) and Terrorist Financing Act, Part 1, und zugehörige Verordnungen
Action
Fine
Status of proceedings
under appeal
Sector
Construction and real estate
Published
12 Feb 2026

Original amount 107,250 CAD, converted at the ECB reference rate of 27 Nov 2025.

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

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24 Nov 2025 FWS Group LtdADGM: allegedly 51,000 USD fine for business centre operator FWS Group over missing customer checks United Arab EmiratesCustomer due diligence €44,179

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the operator of a business centre, registered as a company service provider, allegedly 51,000 USD for anti-money laundering failings between December 2022 and December 2023. The firm had not carried out a business risk assessment and could not show a risk assessment for any of its 104 customers (tenants), nor had it verified any of them, because its outsourced compliance provider treated only the external operator of the centre as a customer; in addition, after the money laundering reporting officer (MLRO) had been absent for a long period, a replacement was only appointed after about ten months and the regulator was not promptly informed. Without the 20% discount for early settlement the fine would have been 63,750 USD.

What organisations can take from it

A firm that outsources operations and compliance remains itself responsible for due diligence on all of its own customers.

Relevance to training and awareness

Who the customer is: due diligence duties when operations and compliance are outsourced

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Section 232 FSMR 2015; AML Rules 4.1.1(1), 4.1.1(2)(a) und (d), 6.1.1, 7.1.1(1)(a) und (b), 7.1.2(1)(a), 8.3.1(1)(d), 8.3.2, 8.4.1(c), 12.1.1(1), 15.6.1(d)
Action
Fine
Status of proceedings
final
Sector
Other
Repeat case
no
Mitigating circumstances
No previous non-compliance, cooperation and a remediation programme; 20% discount for early settlement.

Original amount 51,000 USD, converted at the ECB reference rate of 24 Nov 2025.

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 USA, NVCustomer due diligence €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).

What organisations can take from it

Casino staff must recognise high-risk players and unexplained sources of funds – revenue interests must not override AML obligations.

Relevance to training and awareness

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.

Checked against the official source on 27 Sep 2026 · Version 2 · Direct link

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20 Nov 2025 MP Technology Services Ltd.FINTRAC: CAD 536,853.35 penalty on MP Technology Services Ltd. for 4 violations of anti-money laundering obligations CanadaSuspicious activity reports €331,514

According to FINTRAC, MP Technology Services Ltd. is an entity determined to be a foreign money services business operating in Canada. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 536,853.35 on the company on 20 November 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 4 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned international electronic funds transfer reporting, written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks and suspicious transaction reporting. Specifically, FINTRAC found four unreported incoming international transfers and four unreported suspicious attempted transactions; policies and risk assessment were not tailored to Canadian requirements. According to FINTRAC, the company has appealed the decision to the Federal Court. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on MP Technology Services Ltd.", published 18 December 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-12-18-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9(1), 9.6(1), 9.6(2); PCMLTF Regulations 30(1)(c), 156(1)(b), 156(1)(c); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
18 Dec 2025

Original amount 536,853.35 CAD, converted at the ECB reference rate of 20 Nov 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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20 Nov 2025 1135233 B.C. Ltd.FINTRAC: CAD 149,886 penalty on 1135233 B.C. Ltd. for 6 violations of anti-money laundering obligations CanadaSuspicious activity reports €92,557

According to FINTRAC, 1135233 B.C. Ltd. (operating as LeHomes Realty Premier) is a real estate brokerage based in Vancouver, British Columbia. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 149,886 on the company. Published by FINTRAC on 20 November 2025; decision date not published. According to FINTRAC's findings, the company committed 6 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, appointing a compliance officer, written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the compliance training programme and client identification record keeping. According to FINTRAC, the company will pay the penalty in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on 1135233 B.C. Ltd.", published 20 November 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-11-20-3-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7; PCMLTF Regulations 39(1)(b), 71(1)(a), 71(1)(b), 71(1)(c), 71(1)(d); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Published
20 Nov 2025

Original amount 149,886 CAD, converted at the ECB reference rate of 20 Nov 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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13 Nov 2025 TMF Management B.V.OM: €130,500 for trust office TMF over unreported transactions NetherlandsSuspicious activity reports €130,500

The Openbaar Ministerie (OM, Dutch Public Prosecution Service) imposed a penalty order of 130,500 EUR on TMF Management B.V. because the trust office did not immediately report two unusual transactions by a client to FIU-NL in 2020 and 2021. TMF continued to work on the (re)structuring of that client’s bond issue although, from 2020, it was aware of negative media reports about pending court cases over suspected fraud by the client; the proceedings stemmed from a report by De Nederlandsche Bank (Dutch central bank). Because of the exemplary role of the internationally active trust office, the OM raised the fine category and granted a 25% reduction for voluntary, full and timely cooperation.

What organisations can take from it

Negative press reports about a client are a reason to reassess ongoing transactions and report anything unusual without delay.

Relevance to training and awareness

Negative media reports as a trigger for suspicious transaction reports

Authority / court
Openbaar Ministerie (OM), Functioneel Parket
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft), Pflicht zur unverzüglichen Meldung ungewöhnlicher Transaktionen; Strafbefehl des OM
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Voluntary, full and timely cooperation (−25%).
Published
13 Nov 2025

Checked against the official source on 2 Oct 2026 · Direct link

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5 Nov 2025 Coinbase Europe LimitedIreland: 21.5 million EUR against Coinbase Europe – 30 million transactions unchecked IrelandInternal controls €21.5m

In a settlement of 5 November 2025, the Central Bank of Ireland imposed a reprimand and 21,464,734 EUR (after a 30% discount on 30,663,906 EUR) for breaches of transaction monitoring obligations between April 2021 and March 2025: because of configuration errors in the monitoring system, more than 30 million transactions worth over 176 billion EUR – around 31% of all transactions – were not properly monitored over a period of twelve months. The subsequent review took almost three years and led to 2,708 suspicious transaction reports; the High Court confirmed the sanction on 12 January 2026, and it is the Central Bank's first enforcement action in the crypto sector.

What organisations can take from it

Test monitoring rules regularly for complete coverage – a silent configuration error can go undetected for years.

Authority / court
Central Bank of Ireland
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Criminal Justice (Money Laundering and Terrorist Financing) Act 2010
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
30% settlement discount
Published
6 Nov 2025
Sources

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

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28 Oct 2025 Landesbank Hessen-Thüringen Girozentrale (Helaba)BaFin: fine against Helaba over inadequate monitoring systems for money laundering prevention GermanyInternal controls €20,000

By decision of 28 October 2025 (final since 7 November 2025), Germany's Federal Financial Supervisory Authority (BaFin) imposed a fine of 20,000 EUR because, from October 2022 to September 2023, the Landesbank operated data processing systems for money laundering prevention that were only partially adequate. Under the German Banking Act (KWG), the criteria by which monitoring identifies suspicious transactions must be documented, and the systems must be checked regularly by an independent auditor.

What organisations can take from it

Transaction monitoring needs documented indicators and a regular independent quality review – the mere existence of software is not enough.

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
§ 56 Abs. 2 Nr. 11b KWG (Betrieb angemessener Datenverarbeitungssysteme zur Geldwäscheprävention)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
10 Dec 2025

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

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17 Oct 2025 Griffin Jewellery Designs Inc.FINTRAC: CAD 77,137.50 penalty on Griffin Jewellery Designs Inc. for 3 violations of anti-money laundering obligations CanadaInternal controls €47,055

According to FINTRAC, Griffin Jewellery Designs Inc. is a dealer in precious metals and stones. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 77,137.50 on the company on 17 October 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 3 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks and the prescribed review of the compliance programme. According to FINTRAC, the company is paying the penalty in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Griffin Jewellery Designs Inc.", published 4 December 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-12-04-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 9.6(1), 9.6(2); PCMLTF Regulations 156(1)(b), 156(1)(c), 156(1)(f); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Published
4 Dec 2025

Original amount 77,137.5 CAD, converted at the ECB reference rate of 17 Oct 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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17 Oct 2025 Access Forex (Pty) LimitedAccess Forex: ZAR 162,500 on foreign exchange dealer for AML failings South AfricaInternal controls €8,005

The authorised dealer in foreign exchange with limited authority (ADLA, a category that includes bureaux de change) had not incorporated key requirements of the FIC Act into its risk management and compliance programme, had failed to identify and verify some customers and had not given its staff adequate training. The penalties amount to 100,000 ZAR (section 42(1)), 37,500 ZAR (section 20) and 25,000 ZAR (section 43), 162,500 ZAR in total. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Foreign exchange dealers and bureaux de change, too, must align their compliance programme with all statutory duties and train their staff regularly.

Relevance to training and awareness

Customer identification and mandatory training at foreign exchange dealers

Missing or inadequate training played a role in the decision.

Authority / court
South African Reserve Bank (SARB)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Sections 20, 42(1) und 43 Financial Intelligence Centre Act 38 of 2001
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
17 Oct 2025

Original amount 162,500 ZAR, converted at the ECB reference rate of 17 Oct 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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16 Oct 2025 Xeltox Enterprises Ltd. (Cryptomus)FINTRAC: record penalty of 177 million CAD against crypto payment service Cryptomus CanadaSuspicious activity reports €108.1m

The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) imposed 176,960,190 CAD on the crypto payment service registered in British Columbia. In July 2024 alone, 1,068 suspicious transaction reports were not filed – including on transactions linked to child sexual abuse material, fraud, ransomware and sanctions evasion – as well as 1,518 reports of large virtual currency transactions; in addition, there were violations of a ministerial directive and a lack of policies and risk assessment. The company has appealed to the Federal Court.

What organisations can take from it

Crypto services without a functioning reporting system are sanctioned per report not filed – the total can threaten their existence.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Proceeds of Crime (Money Laundering) and Terrorist Financing Act, Part 1, und zugehörige Verordnungen
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
22 Oct 2025

Original amount 176,960,190 CAD, converted at the ECB reference rate of 16 Oct 2025.

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

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15 Oct 2025 Zimpler ABZimpler: 3 million SEK over anti-money laundering deficiencies at gambling-related payment service SwedenCustomer due diligence €272,245

Between July 2023 and April 2024, the payment service provider, a substantial part of whose business is linked to the gambling sector, had gaps in its general risk assessment (including a missing assessment of its currency exchange service), in its customer risk assessment and in customer due diligence. The Swedish financial supervisory authority Finansinspektionen (FI) issued a remark and imposed 3 million SEK.

What organisations can take from it

Include every new product – even an ancillary service such as currency exchange – in the money laundering risk assessment before launch.

Relevance to training and awareness

Money laundering risks in the gambling environment

Authority / court
Finansinspektionen (FI)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Penningtvättslagen (2017:630)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
15 Oct 2025

Original amount 3,000,000 SEK, converted at the ECB reference rate of 15 Oct 2025.

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

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13 Oct 2025 J.P. Morgan SEBaFin: 45 million EUR against J.P. Morgan SE over late suspicious activity reports GermanySuspicious activity reports €45m

By decision of 13 October 2025 (final since 30 October 2025), Germany's Federal Financial Supervisory Authority (BaFin) imposed a fine of 45 million EUR on J.P. Morgan SE because the institution had culpably breached its duty of supervision in the internal processes for filing money laundering suspicious activity reports; from 4 October 2021 to 30 September 2022, suspicious activity reports were systematically not filed on time. BaFin points out that, in the case of systematic infringements, the amount of the fine can be based on the institution's total turnover.

What organisations can take from it

File suspicious activity reports without delay – systematic backlogs in the reporting process are themselves an infringement, and the fine can then be calculated on the basis of the institution's total turnover.

Relevance to training and awareness

Filing money laundering suspicious activity reports without delay

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
§ 130 Abs. 1 OWiG (Aufsichtspflichtverletzung) i. V. m. Pflichten nach dem GwG (Verdachtsmeldungen); Bekanntmachung nach § 57 Abs. 1 GwG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
6 Nov 2025

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

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13 Oct 2025 Sanlam Collective Investments (RF) (Pty) LtdSanlam Collective Investments: ZAR 10.6m for breaches of anti-money laundering duties South AfricaCustomer due diligence €527,691

An inspection in March 2024 showed that the manager of collective investment schemes was not applying its risk management and compliance programme (RMCP) effectively, particularly when risk-rating clients, that the programme had substantive gaps, that some clients and their beneficial owners had not been adequately identified and verified, and that the required ongoing and enhanced due diligence was missing. Alongside a directive to remediate and a caution, a penalty of 10.6 million ZAR was imposed, of which 3.6 million ZAR is conditionally suspended for two years; earlier contraventions of other laws were taken into account, including an enforceable undertaking and a penalty under the Collective Investment Schemes Control Act (CISCA). The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Large group companies are held to higher standards – a documented programme without risk rating in practice does not protect against substantial penalties.

Relevance to training and awareness

Client risk rating and ongoing and enhanced due diligence

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Sections 42(1), 42(2), 20A, 21, 21A, 21B, 21C, 21E und 21F–21H Financial Intelligence Centre Act 38 of 2001 (FIC Act)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
Remedial action taken to date; 3.6 million ZAR suspended for two years, provided the deficiencies are fully remedied and the obligations are complied with on a sustained basis.
Published
13 Oct 2025

Original amount 10,600,000 ZAR, converted at the ECB reference rate of 13 Oct 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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9 Oct 2025 Rakuten Europe Bank S.A.Rakuten Europe Bank: EUR 185,000 for outdated transaction monitoring LuxembourgInternal controls €185,000

The CSSF fined the bank EUR 185,000, around 1% of its annual turnover. The 2023 inspection revealed a monitoring system that was no longer maintained, thousands of unprocessed screening alerts (including on financial sanctions and PEPs), late suspicious activity reports and incorrect risk ratings. Several failings had already been raised by another European supervisory authority in 2020 without the bank remedying them effectively.

What organisations can take from it

Monitoring tools need maintained scenarios and staff who understand them – a backlog of sanctions-screening alerts is itself a breach.

Relevance to training and awareness

Loss of know-how on monitoring tools and backlogs of screening alerts

Authority / court
Commission de Surveillance du Secteur Financier (CSSF)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 2-1(1) i. V. m. Art. 8-4(1), (2)(f) und (3)(a) Loi modifiée du 12 novembre 2004 (LBC/FT); Règlement grand-ducal du 1er février 2010; Règlement CSSF 12-02
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
Limited scope of the inspection; the bank acknowledged the breaches, provided an action plan and started remediation.
Published
6 Jan 2026

Checked against the official source on 2 Oct 2026 · Direct link

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7 Oct 2025 Paywiser LimitedFCA halts e-money institution Paywiser and bans unregistered cryptoasset business United KingdomInternal controls Order

The FCA barred Paywiser Limited, an authorised e-money institution, with immediate effect from providing e-money and payment services to new and existing customers and, by a direction under the money laundering rules, also prohibited it from carrying on cryptoasset business without registration. The FCA had serious concerns about its risk management and internal controls, did not consider its sole shareholder fit and proper, saw indications of unregistered cryptoasset business and criticised a lack of openness with the regulator.

What organisations can take from it

New lines of business such as cryptoasset services need their own registration before launch – an existing e-money authorisation does not cover them.

Relevance to training and awareness

Registration requirements for cryptoasset services

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
reg. 11(1) Electronic Money Regulations 2011; regs. 56(1)(f) und 74C Money Laundering Regulations 2017; Principle 11 der FCA Principles for Businesses
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance

Checked against the official source on 3 Oct 2026 · Direct link

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30 Sep 2025 Payabl. Cy Ltd (vormals Powercash21 Ltd)Payabl. Cy fined EUR 350,000 for AML failings by Central Bank of Cyprus CyprusMoney laundering and terrorist financing €350,000

On the basis of an examination carried out in 2020, the Central Bank of Cyprus imposed a fine of EUR 350,000 on Payabl because the company had failed to comply with certain provisions of the money laundering law; the announcement does not give details. Payabl lodged an appeal with the Administrative Court on 12 December 2025. The decision is not final.

What organisations can take from it

Supervisory examinations can lead to fines years later – findings should be remediated and documented straight away.

Relevance to training and awareness

Anti-money laundering duties of firms supervised by the central bank

Authority / court
Central Bank of Cyprus (Κεντρική Τράπεζα της Κύπρου)
Area of law
Money laundering and terrorist financing
Legal basis
Section 59(6) Prevention and Suppression of Money Laundering Activities Law of 2007
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
3 Oct 2025

Checked against the official source on 28 Sep 2026 · Direct link

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26 Sep 2025 Synergy Credit UnionFINTRAC: CAD 214,500 penalty on Synergy Credit Union for 4 violations of anti-money laundering obligations CanadaSuspicious activity reports €131,757

According to FINTRAC, Synergy Credit Union is a provincially regulated credit union based in Lloydminster, Saskatchewan. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 214,500 on the company on 26 September 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 4 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, assessing and documenting money laundering and terrorist financing risks, enhanced measures for high risk and written compliance policies and procedures. Specifically, according to FINTRAC, the credit union failed to report suspicious transactions in two instances; contrary to its own policies, 46 of 102 high-risk clients were not reviewed annually. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Synergy Credit Union", published 27 November 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-11-27-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9.6(1), 9.6(3); PCMLTF Regulations 156(1)(b), 156(1)(c), 157; PCMLTF Suspicious Transaction Reporting Regulations s. 9(1); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
27 Nov 2025

Original amount 214,500 CAD, converted at the ECB reference rate of 26 Sep 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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22 Sep 2025 Platinum Gaming LimitedPlatinum Gaming (Unibet): £10m fine for AML and player protection failings United KingdomInternal controls €11.5m

The Gambling Commission imposed a financial penalty of £10,000,000, a warning and an additional licence condition requiring an external audit on the operator of unibet.co.uk and uk.bingo.com. Between January 2023 and May 2024, its money laundering risk assessment did not take account of accounts previously closed over money laundering or terrorist financing concerns, so blocked customers could open new accounts; the AML policy was unclear about which level of due diligence applied when, and customers showing clear signs of harm were not contacted. It is the second enforcement action against the company, following one in 2023.

What organisations can take from it

Anyone closing accounts over money laundering concerns must technically prevent the same customers from returning with new accounts.

Relevance to training and awareness

Recognising blocked customers and timely customer interaction where there are signs of harm

Authority / court
Gambling Commission
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
LC 12.1.1 Abs. 1–3 und LC 12.1.2 sowie SRCP 3.4.3 der Licence Conditions and Codes of Practice (LCCP); s. 117(1)(a) und (b) Gambling Act 2005
Action
Fine
Status of proceedings
unknown
Sector
Other
Repeat case
yes
Mitigating circumstances
The company cooperated throughout the investigation.
Published
22 Oct 2025

Original amount 10,000,000 GBP, converted at the ECB reference rate of 22 Sep 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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22 Sep 2025 First Nations Bank of CanadaFINTRAC: CAD 601,139.80 penalty on First Nations Bank of Canada for 5 violations of anti-money laundering obligations CanadaSuspicious activity reports €369,432

According to FINTRAC, First Nations Bank of Canada is a bank based in Saskatoon, Saskatchewan. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 601,139.80 on the company on 22 September 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 5 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, enhanced measures for high-risk situations and ongoing monitoring of business relationships. Specifically, according to FINTRAC, suspicious transaction reports were missing in 5 of 16 case files reviewed; in six instances reviewed, high-risk clients were not subject to special measures. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on First Nations Bank of Canada", published 16 October 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-10-16-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9.6(1), 9.6(3); PCMLTF Regulations 123.1, 156(1)(b), 156(1)(c), 157; PCMLTF Suspicious Transaction Reporting Regulations s. 9(1); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
16 Oct 2025

Original amount 601,139.8 CAD, converted at the ECB reference rate of 22 Sep 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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8 Sep 2025 Crédit Agricole Corporate and Investment Bank (Crédit Agricole CIB)PNF: Crédit Agricole CIB pays €88.25m over cum-cum dividend trades FranceMoney laundering and terrorist financing €88.2m

Crédit Agricole CIB concluded a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement) with the Parquet national financier (PNF, French national financial prosecutor) over suspected aggravated laundering of aggravated tax fraud through dividend arbitrage (cum-cum) and pays a public interest fine of 88,247,869 EUR. Including the taxes, interest and penalties paid in the tax proceedings, the prosecutor puts the overall sum at 134,432,437 EUR; the agreement was validated on 8 September 2025.

What organisations can take from it

Trading structures whose economic purpose is mainly to avoid withholding tax are a criminal risk and belong in the compliance approval process.

Relevance to training and awareness

Tax-driven trading structures (cum-cum) as a criminal and money laundering risk

Authority / court
Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
Area of law
Money laundering and terrorist financing
Legal basis
Art. 41-1-2 Code de procédure pénale (blanchiment aggravé de fraude fiscale aggravée)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
8 Sep 2025

Checked against the official source on 2 Oct 2026 · Direct link

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2 Sep 2025 Commerciale I.C. - Pacific Inc.FINTRAC: CAD 224,235 penalty on Commerciale I.C. - Pacific Inc. for 5 violations of anti-money laundering obligations CanadaInternal controls €139,658

According to FINTRAC, Commerciale I.C. - Pacific Inc. is a money services business based in Montréal, Quebec. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 224,235 on the company on 2 September 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 5 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned international electronic funds transfer reporting, written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the prescribed review of the compliance programme and compliance with a ministerial directive. Specifically, according to FINTRAC, 8 of 22 electronic funds transfer reports reviewed were not filed on time; the company also did not comply with a ministerial directive. According to FINTRAC, the company has appealed the decision to the Federal Court. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Commerciale I.C. - Pacific Inc.", published 5 February 2026, https://fintrac-canafe.canada.ca/pen/amps/pen-2026-02-05-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 11.43; PCMLTF Regulations 132(1), 156(1)(b), 156(1)(c), 156(1)(f); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
5 Feb 2026

Original amount 224,235 CAD, converted at the ECB reference rate of 2 Sep 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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29 Aug 2025 Juba Express Inc.FINTRAC: CAD 67,150 penalty on Juba Express Inc. for 5 violations of anti-money laundering obligations CanadaInternal controls €41,888

According to FINTRAC, Juba Express Inc. is a money services business based in Toronto, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 67,150 on the company on 29 August 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 5 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, international electronic funds transfer reporting, large cash transaction reporting and money services business registration requirements. Specifically, according to FINTRAC, nine electronic funds transfer reports and three large cash transaction reports were incomplete; one branch was not disclosed in the registration. According to FINTRAC, the company has appealed the decision to the Federal Court. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Juba Express Inc.", published 11 December 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-12-11-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 9(1); PCMLTF Regulations 30(1)(a), 30(1)(b), 156(1)(b), 156(1)(c), 156(2); PCMLTF Registration Regulations s. 4(b), 5; Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
11 Dec 2025

Original amount 67,150 CAD, converted at the ECB reference rate of 29 Aug 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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28 Aug 2025 Saskatchewan Indian Gaming AuthorityFINTRAC: CAD 1,175,000 penalty on Saskatchewan Indian Gaming Authority for 3 violations of anti-money laundering obligations CanadaSuspicious activity reports €731,540

According to FINTRAC, Saskatchewan Indian Gaming Authority is a reporting entity in the casino sector. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 1,175,000 on the company on 28 August 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 3 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting and written compliance policies and procedures. Specifically, according to FINTRAC, four suspicious transaction reports were missing, three reports filed contained no indicators of suspicion, and the regulator found shortcomings in patron risk rating in 41 of 100 instances reviewed. According to FINTRAC, the company has appealed the decision to the Federal Court. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Saskatchewan Indian Gaming Authority", published 12 September 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-09-12-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9(1), 9.6(1); PCMLTF Regulations 156(1)(b); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Other
Published
12 Sep 2025

Original amount 1,175,000 CAD, converted at the ECB reference rate of 28 Aug 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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26 Aug 2025 UHY James Chartered AccountantsADGM: allegedly 20,400 USD fine for audit firm UHY James over unresolved screening alerts United Arab EmiratesInternal controls €17,502

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the registered auditor in ADGM, a branch of a foreign company, allegedly 20,400 USD for anti-money laundering failings between February 2022 and February 2024. In seven of 28 customer files reviewed, 397 screening alerts relating to four customers remained unresolved after a change of screening software, positive matches were dismissed without adequate justification, media reports alleging possible evasion of non-UAE sanctions by one customer were missed, the business risk assessment contained no assessment of targeted financial sanctions risk, and the source of funds and wealth of politically exposed persons was not verified. Without the 20% discount for early settlement the fine would have been 25,500 USD.

What organisations can take from it

Screening alerts must be resolved and closed with a documented rationale, especially after a system change.

Relevance to training and awareness

Name and sanctions screening: resolving and documenting alerts

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Section 232 FSMR 2015; AML Rules 4.1.1(1), 4.1.1(2)(a) und (d), 6.1.1, 7.1.1, 7.1.2(1)(a), 7.1.3, 8.3.1(1)(b), 8.3.2, 8.4.1(c), 8.6.1, 11.2.1(1); Art. 21 Cabinet Decision No. 74 of 2020
Action
Fine
Status of proceedings
final
Sector
Other
Repeat case
no
Mitigating circumstances
No previous breaches of the AML rules, cooperation and substantial remediation (15% reduction); 20% discount for early settlement; the failings concerned only the ADGM entity and no other entities of the UHY group.

Original amount 20,400 USD, converted at the ECB reference rate of 26 Aug 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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22 Aug 2025 Varengold Bank AGBaFin: 3.3 million EUR fine and penalty payment against Varengold Bank GermanySuspicious activity reports €3.8m

By decision of 22 August 2025, Germany's Federal Financial Supervisory Authority (BaFin) imposed a fine of 3.3 million EUR because the bank systematically filed suspicious activity reports late from June 2023 to March 2025; in February 2025, a penalty payment of 500,000 EUR had already been imposed for failure to comply with a 2023 order concerning Iran-related transactions (total 3.8 million EUR). In addition, in July 2025 BaFin ordered comprehensive remediation of the deficiencies in money laundering prevention, with an action plan and reporting obligations.

What organisations can take from it

Failing to implement a supervisory order risks penalty payments and a comprehensive package of measures in addition to the fine.

Relevance to training and awareness

Suspicious activity reports and handling of high-risk transactions

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Bußgeld: § 56 Abs. 1 S. 1 Nr. 69, Abs. 3 GwG; Anordnung: § 51 Abs. 2 GwG, § 44 Abs. 1 KWG; Zwangsgeld: § 14 VwVG i. V. m. § 17 FinDAG; Bekanntmachung nach § 57 Abs. 1 GwG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Published
16 Sep 2025

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

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22 Aug 2025 Bank J. Safra Sarasin AGBank J. Safra Sarasin: 3.5 million CHF fine for money laundering in the Petrobras complex SwitzerlandInternal controls €3.73m

Between 2011 and 2014, the bank did not take all the necessary organisational precautions, with the result that bribes flowed to Petrobras executives through several account relationships (around 71 million USD in attempted or completed aggravated money laundering). Fine of 3.5 million CHF; because of a settlement of 16 million CHF with Petrobras, the Office of the Attorney General of Switzerland (Bundesanwaltschaft, OAG) waived a compensation claim.

What organisations can take from it

Unusual payment flows involving clients close to PEPs must be escalated and, if necessary, rejected – responsibility lies with the bank as an organisation.

Relevance to training and awareness

Anti-money laundering and PEP clients

Authority / court
Bundesanwaltschaft
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 102 Abs. 2 StGB i. V. m. Art. 305bis Abs. 1 und 2 StGB
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Time elapsed since the offence, organisational corrective measures after the affair became known; no compensation claim because of the payment of 16 million CHF to Petrobras.
Published
22 Aug 2025

Original amount 3,500,000 CHF, converted at the ECB reference rate of 22 Aug 2025.

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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22 Aug 2025 J.P. Morgan (Suisse) SAJ.P. Morgan (Suisse): 3 million CHF fine in the 1MDB complex for deficient anti-money laundering controls SwitzerlandCustomer due diligence €3.2m

Between October 2014 and July 2015, around 174 million CHF from predicate offences in the 1MDB complex passed through the bank in 43 transfers, even though negative information about the Petrosaudi managers involved was publicly available. The Office of the Attorney General of Switzerland (Bundesanwaltschaft) convicted the bank by summary penalty order and imposed 3 million CHF; a compensation claim was waived because the 1MDB fund is being compensated as a private claimant.

What organisations can take from it

Publicly available negative information about clients must feed into the risk assessment and be capable of stopping transactions.

Relevance to training and awareness

Customer due diligence and adverse media screening

Authority / court
Bundesanwaltschaft
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 102 Abs. 2 StGB i. V. m. Art. 305bis Abs. 1 und 2 StGB
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Time elapsed since the offence, very good cooperation in the proceedings, compensation of the private claimant (1MDB).
Published
22 Aug 2025

Original amount 3,000,000 CHF, converted at the ECB reference rate of 22 Aug 2025.

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

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18 Aug 2025 Morpheus Software Technology FZE (Fuze)VARA sanctions crypto provider Fuze over AML failings and activity outside its licence United Arab EmiratesInternal controls Fine

An investigation by the Virtual Assets Regulatory Authority (VARA, Dubai's virtual assets regulator) that began on 15 April 2025 found failures in the anti-money laundering programme, governance, compliance and internal controls of Morpheus Software Technology FZE (Fuze), licensed since October 2023. The company had also intentionally carried out virtual asset activities in breach of its licence conditions and failed to disclose material facts to the regulator. VARA imposed a fine of an undisclosed amount, issued a cease-and-desist order according to its enforcement list, and ordered the appointment of a Skilled Person to oversee remediation.

What organisations can take from it

Licensed providers must stay within the scope of their licence and disclose material facts to the regulator – otherwise fines and external monitoring follow.

Relevance to training and awareness

AML programme, licence boundaries and disclosure to the regulator

Authority / court
Virtual Assets Regulatory Authority (VARA), Dubai
Area of law
Money laundering and terrorist financing · Internal controls
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
intentional
Mitigating circumstances
The company accepted the findings and proposed a remediation plan.
Published
18 Aug 2025

Checked against the official source on 3 Oct 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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31 Jul 2025 Gomti ExchangeCBUAE revokes Gomti Exchange's licence over AML and sanctions failings United Arab EmiratesInternal controls Other

The Central Bank of the UAE (CBUAE) revoked the licence of the exchange house Gomti Exchange and struck it off the register (Article 137 of Decretal Federal Law No. 14 of 2018). Examinations had found significant failures by the company to comply with the framework for combating money laundering and the financing of terrorism and illegal organisations and with the sanctions framework.

What organisations can take from it

For exchange houses, anti-money laundering and sanctions compliance are at the core of licence obligations – significant gaps can lead to the loss of authorisation.

Relevance to training and awareness

AML and sanctions compliance at exchange houses

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 137 Decretal Federal Law No. (14) of 2018 regarding the Central Bank and Organisation of Financial Institutions and Activities
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
31 Jul 2025

Checked against the official source on 3 Oct 2026 · Direct link

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30 Jul 2025 Al Nahdi ExchangeCBUAE revokes Al Nahdi Exchange's licence over AML and sanctions failings United Arab EmiratesInternal controls Other

Central Bank examinations found significant failures by the exchange house to comply with the framework for combating money laundering, terrorist financing and illegal organisations and with sanctions requirements. The CBUAE revoked the licence and struck the exchange house off the register.

What organisations can take from it

Where AML and sanctions compliance is seriously deficient, payment service providers face not just a fine but the end of their licence.

Relevance to training and awareness

AML and sanctions compliance in exchange houses

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 137 Decretal Federal Law No. (14) of 2018 regarding the Central Bank and Organisation of Financial Institutions and Activities
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
30 Jul 2025

Checked against the official source on 3 Oct 2026 · Direct link

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28 Jul 2025 Peken Global Limited (KuCoin)FINTRAC: CAD 19,552,000 penalty on Peken Global Limited (KuCoin) for 3 violations of anti-money laundering obligations CanadaSuspicious activity reports €12.2m

According to FINTRAC, Peken Global Limited (KuCoin) is an entity determined to be a foreign money services business operating in Canada. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 19,552,000 on the company on 28 July 2025. According to FINTRAC's findings, the company committed 3 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned money services business registration requirements, large virtual currency transaction reporting and suspicious transaction reporting. Specifically, FINTRAC found 33 instances of unreported suspicious transactions; the regulator identified unreported virtual currency receipts of CAD 10,000 or more using blockchain analytics, and registration as a foreign money services business was not completed despite the opportunity to do so. According to FINTRAC, the company has appealed the decision to the Federal Court. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Peken Global Limited", published 25 September 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-09-25-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 11.1; PCMLTF Regulations 33(1)(f); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
25 Sep 2025

Original amount 19,552,000 CAD, converted at the ECB reference rate of 28 Jul 2025.

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28 Jul 2025 2294235 Ontario Inc.FINTRAC: CAD 70,537.50 penalty on 2294235 Ontario Inc. for 6 violations of anti-money laundering obligations CanadaCustomer due diligence €44,108

According to FINTRAC, 2294235 Ontario Inc. is a money services business based in Niagara Falls, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 70,537.50 on the company on 28 July 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 6 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the compliance training programme, the prescribed review of the compliance programme, providing documents requested by notice and record keeping. The publication does not mention any pending review. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on 2294235 Ontario Inc.", published 2 December 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-12-02-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
PCMLTFA s. 9.6(2), 63.1(2); PCMLTF Regulations 36(i), 156(1)(b), 156(1)(c), 156(1)(d), 156(1)(e), 156(1)(f), 156(2), 156(3); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
2 Dec 2025

Original amount 70,537.5 CAD, converted at the ECB reference rate of 28 Jul 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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25 Jul 2025 Lizenziertes Finanzdienstleistungsunternehmen (anonymisiert)SCA fines licensed company AED 5m United Arab EmiratesMoney laundering and terrorist financing €1.16m

The Securities and Commodities Authority (SCA, the UAE's federal securities regulator) fined an unnamed company it had licensed AED 5 million. According to its investigation, the company had breached rules on combating money laundering, terrorist financing and the financing of illegal organisations and, together with a foreign company, had misled investors in the UAE by suggesting that the foreign company was licensed by the SCA, with the aim of misappropriating client funds.

Relevance to training and awareness

Misrepresentation of licensing status and AML obligations

Authority / court
Securities and Commodities Authority (SCA)
Area of law
Money laundering and terrorist financing
Legal basis
Vorschriften der VAE zur Bekämpfung von Geldwäsche, Terrorismusfinanzierung und Finanzierung illegaler Organisationen (in der Mitteilung nicht näher bezeichnet)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
intentional
Published
25 Jul 2025

Original amount 5,000,000 AED, converted at the ECB reference rate of 25 Jul 2025.

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25 Jul 2025 DMCL Chartered Professional AccountantsFINTRAC: accountancy firm DMCL without compliance programme – 72,750 CAD CanadaInternal controls €45,370

The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) imposed 72,750 CAD on the auditing and accountancy firm with four offices in British Columbia: approved written compliance policies, a documented risk assessment and the prescribed two-yearly effectiveness review were all lacking. The penalty was paid.

What organisations can take from it

Firms that handle money movements for clients are themselves obliged entities and need their own AML programme.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Proceeds of Crime (Money Laundering) and Terrorist Financing Act, Part 1, und zugehörige Verordnungen
Action
Fine
Status of proceedings
final
Sector
Other
Published
9 Oct 2025

Original amount 72,750 CAD, converted at the ECB reference rate of 25 Jul 2025.

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22 Jul 2025 Indian Overseas Bank, Hong Kong BranchIndian Overseas Bank (Hong Kong): HKD 8.5m penalty and orders over monitoring failings Hong KongInternal controls €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.

What organisations can take from it

A monitoring system only protects the bank if senior management ensures that its alerts are handled by competent staff.

Relevance to training and awareness

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.

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 Hong KongCustomer due diligence €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.

What organisations can take from it

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.

Relevance to training and awareness

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.

Checked against the official source on 3 Oct 2026 · Direct link

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17 Jul 2025 British Columbia Lottery CorporationFINTRAC: CAD 1,075,000 penalty on British Columbia Lottery Corporation for 3 violations of anti-money laundering obligations CanadaSuspicious activity reports €674,531

According to FINTRAC, British Columbia Lottery Corporation is a reporting entity in the casino sector based in Kamloops, British Columbia. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 1,075,000 on the company on 17 July 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 3 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, written compliance policies and procedures and enhanced measures for high-risk situations. Specifically, according to FINTRAC, two suspicious transaction reports were missing; the corporation also failed to identify a patron as high risk despite the rate of play and volume of funds and did not apply enhanced due diligence. According to FINTRAC, the company has appealed the decision to the Federal Court. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on British Columbia Lottery Corporation", published 28 August 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-08-28-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9.6(1), 9.6(3); PCMLTF Regulations 156(1)(b), 157; Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Other
Published
28 Aug 2025

Original amount 1,075,000 CAD, converted at the ECB reference rate of 17 Jul 2025.

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14 Jul 2025 Barclays Bank PlcFCA: £39.3m fine for Barclays Bank Plc over money laundering risks of a corporate client United KingdomCustomer due diligence €45.4m

On 14 July 2025 the FCA fined Barclays Bank Plc £39,314,700 for breaching Principle 2 (due skill, care and diligence). The FCA found that between January 2015 and April 2021 the bank did not properly identify, assess and monitor the money laundering risks posed by one corporate client: apart from March 2019 to May 2020 it treated the client as low risk without knowing enough about its business or where its wealth and funds came from, and it did not reassess that rating when new warning signs emerged. Barclays settled with the FCA and received a 30% discount; without it the fine would have been £56,163,900.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
FCA Principle 2; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 39,314,700 GBP, converted at the ECB reference rate of 14 Jul 2025.

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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14 Jul 2025 Barclays Bank UK PLCFCA: £3.1m fine for Barclays Bank UK over opening a client money account for a wealth manager United KingdomCustomer due diligence €3.57m

The FCA fined Barclays Bank UK PLC £3,093,600. The FCA found that between January 2021 and April 2023 the bank did not gather sufficient information on the purpose and risks of a client money account it opened for a wealth manager; around £34 million was paid into the account. The FCA saw this as evidence of wider weaknesses in opening such accounts. The bank also agreed a voluntary payment of about £6.3 million for the wealth manager's clients.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
FCA Principle 3; SYSC 6.1.1R; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 3,093,600 GBP, converted at the ECB reference rate of 14 Jul 2025.

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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11 Jul 2025 Canadian National Exhibition AssociationFINTRAC: CAD 199,000 penalty on Canadian National Exhibition Association for 2 violations of anti-money laundering obligations CanadaInternal controls €124,321

According to FINTRAC, Canadian National Exhibition Association is a reporting entity in the casino sector based in Toronto, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 199,000 on the company on 11 July 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 2 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned assessing and documenting money laundering and terrorist financing risks and the prescribed review of the compliance programme. According to FINTRAC, the company has appealed the decision to the Federal Court. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on CNE Casino", published 4 September 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-09-04-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 9.6(1); PCMLTF Regulations 156(1)(c), 156(1)(f); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Other
Published
4 Sep 2025

Original amount 199,000 CAD, converted at the ECB reference rate of 11 Jul 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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10 Jul 2025 Bank (anonymisiert)CBUAE: AED 3m on a bank for breaching AML requirements United Arab EmiratesInternal controls €697,653

Central Bank examinations found that an unnamed bank had not complied with the CBUAE's instructions implementing the anti-money laundering law. The CBUAE imposed a financial sanction of AED 3,000,000.

What organisations can take from it

Supervisory instructions on AML are binding – examinations uncover implementation gaps and lead to financial sanctions.

Relevance to training and awareness

Implementing supervisory AML instructions in banks

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 14 Federal Decree Law No. (20) of 2018 on AML/CFT; Art. 137 Decretal Federal Law No. (14) of 2018 regarding the Central Bank
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
10 Jul 2025

Original amount 3,000,000 AED, converted at the ECB reference rate of 10 Jul 2025.

Checked against the official source on 3 Oct 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

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9 Jul 2025 TreasureMeta CorporationFINTRAC: CAD 24,750 penalty on TreasureMeta Corporation for one violation of anti-money laundering obligations CanadaInternal controls €15,440

According to FINTRAC, TreasureMeta Corporation is a money services business based in Markham, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 24,750 on the company on 9 July 2025. According to FINTRAC's findings, made in the course of its supervisory activity, the company committed one violation of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violation concerned money services business registration requirements. The publication does not mention any pending review. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on TreasureMeta Corporation", published 5 February 2026, https://fintrac-canafe.canada.ca/pen/amps/pen-2026-02-05-1-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTF Registration Regulations s. 4(b), 5; Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
5 Feb 2026

Original amount 24,750 CAD, converted at the ECB reference rate of 9 Jul 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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8 Jul 2025 kompasbank a/skompasbank: DKK 5m for failing to monitor 299 customer relationships DenmarkCustomer due diligence €670,160

kompasbank a/s accepted an administrative fine of 5,000,000 DKK from the Finanstilsynet (Danish Financial Supervisory Authority). Between December 2022 and September 2023 it had not met the requirement of ongoing monitoring for 299 customer relationships; the fine was reduced in view of the bank's financial solidity.

What organisations can take from it

Ongoing monitoring is not a one-off step at account opening; it must demonstrably take place for every customer relationship.

Relevance to training and awareness

Ongoing monitoring of existing customer relationships

Authority / court
Finanstilsynet
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Hvidvaskloven § 11 stk. 1 nr. 5; administratives Bußgeld nach § 78 a hvidvaskloven
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Reduction in view of the bank's financial solidity.
Published
11 Jul 2025

Original amount 5,000,000 DKK, converted at the ECB reference rate of 8 Jul 2025.

Checked against the official source on 28 Sep 2026 · Direct link

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7 Jul 2025 Monzo Bank LimitedFCA: £21 million against Monzo over lax account opening for high-risk customers United KingdomCustomer due diligence €24.5m

The UK Financial Conduct Authority (FCA) imposed £21,091,300 (after a 30% discount) because, from 2018 to 2020, Monzo onboarded customers on the basis of sparse and sometimes obviously implausible information – such as well-known London landmarks given as addresses. Despite a requirement not to take on any more high-risk customers, the bank opened more than 34,000 such accounts up to 2022. According to the annual accounts filed with the UK companies register for financial year 2026, the company had around 4,591 employees.

What organisations can take from it

Automated onboarding needs plausibility checks – and supervisory requirements must be implemented in a technically effective way.

Relevance to training and awareness

Plausibility checks in customer onboarding

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
FCA Principle 3 (PRIN 3); s. 55L FSMA (Verstoß gegen Auflage)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
1,000 to 9,999
Mitigating circumstances
30% settlement discount
Published
8 Jul 2025

Original amount 21,091,300 GBP, converted at the ECB reference rate of 7 Jul 2025.

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4 Jul 2025 Credit Suisse Singapore Branch, United Overseas Bank Limited, UBS AG Singapore Branch u. a. (9 Finanzinstitute)MAS: SGD 27.45m against nine financial institutions after major money laundering case SingaporeCustomer due diligence €18.3m

Following inspections of institutions linked to persons of interest (POIs) in the major money laundering case of August 2023, the Monetary Authority of Singapore (MAS, Singapore's central bank and financial regulator) allegedly imposed composition penalties totalling SGD 27.45 million because existing AML/CFT policies had been implemented poorly or inconsistently – in customer risk assessment, corroboration of source of wealth, transaction monitoring and follow-up after suspicious transaction reports. Breakdown: Credit Suisse Singapore Branch SGD 5.8m, United Overseas Bank SGD 5.6m, UBS AG Singapore Branch SGD 3m, UOB Kay Hian SGD 2.85m, Citibank N.A. Singapore and Citibank Singapore Limited together SGD 2.6m, Bank Julius Baer & Co. Ltd. Singapore Branch SGD 2.4m, Blue Ocean Invest SGD 2.4m, Trident Trust Company (Singapore) SGD 1.8m and LGT Bank (Singapore) SGD 1m. The penalty for Credit Suisse also reflects breaches between November 2017 and October 2023 relating to accounts of certain US customers. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Anti-money laundering policies only protect an institution if relationship managers actually question inconsistencies in the source of wealth and systematically follow up alerts from transaction monitoring.

Relevance to training and awareness

Recognising and escalating red flags in source of wealth and transaction patterns (relationship managers as the first line of defence)

Authority / court
Monetary Authority of Singapore (MAS)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
MAS Notices 626, 1014, SFA04-N02 und TCA-N03; s 27B(2) Monetary Authority of Singapore Act 1970 bzw. s 16(4) Financial Services and Markets Act 2022; Composition nach s 176(1A) MAS Act 1970 bzw. s 177(1) FSMA 2022
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
4 Jul 2025

Original amount 27,450,000 SGD, converted at the ECB reference rate of 4 Jul 2025.

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2 Jul 2025 Swilly Mulroy Credit Union LimitedIreland: small credit union accepted cash from non-members without checks IrelandCustomer due diligence €36,273

Between 2014 and 2021, the credit union solicited cash from persons without an account and accepted 2,329 cash deposits totalling 8.75 million EUR without the required anti-money laundering checks; the board had known about the risk since 2015, and there was no self-reporting. The Central Bank of Ireland imposed a reprimand and 36,273 EUR (after a 30% discount on 51,819 EUR).

What organisations can take from it

Even small cooperative banks must identify cash from non-customers – and would do better to self-report known risks.

Relevance to training and awareness

Identification for cash deposits by non-customers

Authority / court
Central Bank of Ireland
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Criminal Justice (Money Laundering and Terrorist Financing) Act 2010; Credit Union Act 1997
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
30% settlement discount
Liability of senior managers
The board had known about the risks since 2015 without taking remedial action
Published
2 Jul 2025

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2 Jul 2025 9321-0599 Québec Inc.FINTRAC: CAD 23,100 penalty on 9321-0599 Québec Inc. for 2 violations of anti-money laundering obligations CanadaInternal controls €14,401

According to FINTRAC, 9321-0599 Québec Inc. is a real estate brokerage based in Brossard, Québec. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 23,100 on the company on 2 July 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 2 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures and assessing and documenting money laundering and terrorist financing risks. According to FINTRAC, the company has appealed the decision to the Federal Court. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on 9321-0599 Québec Inc.", published 20 November 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-11-20-1-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 9.6(1); PCMLTF Regulations 156(1)(b), 156(1)(c); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Construction and real estate
Published
20 Nov 2025

Original amount 23,100 CAD, converted at the ECB reference rate of 2 Jul 2025.

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1 Jul 2025 Olinda SAS (italienische Niederlassung)Banca d'Italia fines Olinda SAS €390,000 over anti-money laundering failings in Italy ItalyInternal controls €390,000

The Banca d'Italia (Bank of Italy) imposed a fine of 390,000 EUR on Olinda SAS under Art. 62 of Legislative Decree 231/2007 for breaches by its Italian branch. The inspection from 29 January to 19 April 2024 had found shortcomings in customer profiling, customer due diligence, record keeping and suspicious transaction reporting, as well as unreported suspicious transactions. On the same day the authority imposed a further 60,000 EUR in a separate decision (no. 211) for breaches of the transparency rules of the Consolidated Banking Act (TUB).

What organisations can take from it

A branch of a foreign institution must fully implement the host country's anti-money laundering duties in its processes, record keeping and suspicious transaction reporting.

Relevance to training and awareness

Anti-money laundering in branches of foreign institutions

Authority / court
Banca d'Italia
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 7, 16–20, 24, 25, 31, 32, 35, 36 und 62 D.Lgs. 231/2007; Bestimmungen der Banca d'Italia vom 26.03.2019, 30.07.2019 und 24.03.2020
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The remedial action already initiated was taken into account.
Published
29 Sep 2025

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27 Jun 2025 Remsea Pte Ltd, Arcade Plaza Traders Pte Ltd, J-Dee Remittance Services Pte Ltd u. a. (5 Zahlungsinstitute)MAS: 960,000 SGD against five remittance providers for AML failings SingaporeCustomer due diligence €642,871

In examinations of five licensed payment institutions providing cross-border money transfers, the Monetary Authority of Singapore (MAS, Singapore's central bank and financial regulator) found failings in customer due diligence, such as missing residential addresses, no inquiry into beneficial owners, no screening of customers against money laundering risk information sources, unverified authority of persons acting for customers and missing originator or beneficiary information on cross-border wire transfers. On 27 June 2025 it allegedly imposed composition penalties totalling 960,000 SGD: Remsea 280,000, Arcade Plaza Traders 260,000, J-Dee Remittance Services 170,000, Mobile Community Tech 140,000 and OxPay SG 110,000 SGD. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Payment institutions offering cross-border transfers must check customers, representatives and beneficial owners and attach complete originator and beneficiary data to every cross-border transfer.

Relevance to training and awareness

Customer due diligence and complete information on cross-border transfers

Authority / court
Monetary Authority of Singapore (MAS)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
MAS Notice PSN01; s 27B(2) Monetary Authority of Singapore Act bzw. s 16(4) Financial Services and Markets Act 2022; Composition nach s 176(1A) MAS Act 1970 bzw. s 177(1) FSMA 2022
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
27 Jun 2025

Original amount 960,000 SGD, converted at the ECB reference rate of 27 Jun 2025.

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26 Jun 2025 DYS 44 Art Gallery LimitedArt dealer DYS 44 Art Gallery: £158,679 fine for money laundering failings United KingdomInternal controls €185,916

HMRC imposed a penalty of £158,679 under the Money Laundering Regulations 2017 on the gallery, which is supervised for anti-money laundering purposes as an art market participant. The failings concerned risk assessment, policies and controls, staff training, due diligence, the timing of verification and record keeping; no appeal was lodged.

What organisations can take from it

Art dealers too must identify buyers in good time and document every check.

Relevance to training and awareness

Anti-money laundering duties in the art trade, especially timely identity verification

Missing or inadequate training played a role in the decision.

Authority / court
HM Revenue & Customs (HMRC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Reg. 18, 19, 24, 28, 30, 40 und 41 Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Published
26 Jun 2025

Original amount 158,679 GBP, converted at the ECB reference rate of 26 Jun 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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24 Jun 2025 Banca Privata Leasing SpaBanca d'Italia: 60,000 EUR against Banca Privata Leasing over deficiencies in AML organisation ItalyInternal controls €60,000

An on-site inspection from February to May 2024 revealed deficiencies in organisation and internal controls relating to customer profiling, due diligence obligations and active cooperation (suspicious transaction reports). The Bank of Italy (Banca d'Italia) imposed an administrative fine of 60,000 EUR, taking into account the corrective measures taken.

What organisations can take from it

Sound customer profiling is the basis for risk-appropriate due diligence and reporting.

Authority / court
Banca d'Italia
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 62 d.lgs. 231/2007; Verstöße gegen Art. 7, 16–20, 24, 25, 35, 36 d.lgs. 231/2007
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Corrective measures taken

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

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24 Jun 2025 Pacesetter Marketing Ltd.FINTRAC: CAD 41,085 penalty on Pacesetter Marketing Ltd. for 3 violations of anti-money laundering obligations CanadaInternal controls €25,815

According to FINTRAC, Pacesetter Marketing Ltd. is a real estate brokerage based in Vancouver, British Columbia. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 41,085 on the company on 24 June 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 3 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks and the prescribed review of the compliance programme. According to FINTRAC, the company is paying the penalty in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Pacesetter Marketing Ltd.", published 20 November 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-11-20-2-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 9.6(1); PCMLTF Regulations 156(1)(b), 156(1)(c), 156(1)(f), 156(3); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Published
20 Nov 2025

Original amount 41,085 CAD, converted at the ECB reference rate of 24 Jun 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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23 Jun 2025 C2D Payment Solutions LimitedMalta: 243,537 EUR against C2D Payment Solutions for ignoring cash risks MaltaCustomer due diligence €243,537

The financial institution did not take into account its customers’ significant cash exposure in its customer risk assessment, so that almost all customers were rated low risk – even with cash deposits of over 100,000 EUR. The Financial Intelligence Analysis Unit (FIAU) imposed 243,537 EUR and a follow-up directive; the fine was open to appeal at the time of publication.

What organisations can take from it

Cash is an explicit high-risk factor – a risk model that ignores it is worthless.

Relevance to training and awareness

Recognising cash as a risk factor

Authority / court
Financial Intelligence Analysis Unit (FIAU)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Reg. 5(5)(a)(ii), 7(1)(c), 7(1)(d), 7(2)(a), 21 PMLFTR
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
23 Jun 2025

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

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20 Jun 2025 Saxony: 7,000 EUR fine against art dealer over due diligence obligations and risk management GermanyInternal controls €7,000

The Saxony State Directorate (Landesdirektion Sachsen), as anti-money laundering supervisor for the non-financial sector, imposed a fine of 7,000 EUR on an art dealer, announced in anonymised form, for breaches of the due diligence obligations and risk management requirements under the German Money Laundering Act (GwG). The authority had previously issued several orders on risk management in the art trade, backed by the threat of penalty payments.

What organisations can take from it

Art dealers need a written risk analysis and must identify buyers for transactions of 10,000 EUR or more.

Relevance to training and awareness

AML obligations in the art trade

Authority / court
Landesdirektion Sachsen (Geldwäscheaufsicht Nichtfinanzsektor)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Geldwäschegesetz (Sorgfaltspflichten, Risikomanagement); Bekanntmachung nach § 57 GwG
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce

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

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17 Jun 2025 Sundus ExchangeCBUAE revokes Sundus Exchange's licence and fines it AED 10m over AML breaches United Arab EmiratesInternal controls €2.35m

The Central Bank of the UAE (CBUAE) revoked the licence of the exchange house Sundus Exchange, struck it off the register and fined it AED 10 million under Article 14 of the anti-money laundering law (Federal Decree Law No. 20 of 2018). The measures were based on examination findings of failures and breaches of the framework for combating money laundering and the financing of terrorism and illegal organisations.

What organisations can take from it

For payment and exchange businesses, anti-money laundering breaches can lead to a fine and loss of licence at the same time.

Relevance to training and awareness

AML obligations of exchange houses

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 14 Federal Decree Law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
17 Jun 2025

Original amount 10,000,000 AED, converted at the ECB reference rate of 17 Jun 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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17 Jun 2025 Banque Pictet et Cie SABanque Pictet: 2 million CHF fine for laundering Petrobras bribes SwitzerlandInternal controls €2.13m

Between 2010 and 2013, 54 transfers were processed through the bank by which bribes of around 4.1 million USD connected with SBM Offshore's charter contracts with Petrobras were concealed. The bank had not classified high-risk accounts as such and had inadequately monitored transfers; the Office of the Attorney General of Switzerland (Bundesanwaltschaft) imposed a fine of 2 million CHF on the bank.

What organisations can take from it

Risk classification and transaction monitoring must take effect before individual relationship managers approve payments.

Relevance to training and awareness

High-risk clients and transaction monitoring

Authority / court
Bundesanwaltschaft
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 102 Abs. 2 StGB i. V. m. Art. 305bis und Art. 322septies StGB
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Time elapsed since the offence, very good cooperation, organisational corrective measures after the Petrobras affair became known.
Published
17 Jun 2025

Original amount 2,000,000 CHF, converted at the ECB reference rate of 17 Jun 2025.

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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2 Jun 2025 LocalBitcoins OyLocalBitcoins: 500,000 EUR for failing to identify customers when opening accounts FinlandCustomer due diligence €500,000

During an inspection in 2024, the Finanssivalvonta (Finnish Financial Supervisory Authority, FIN-FSA) found that the crypto trading platform had not identified and verified its customers when establishing permanent business relationships. Taking the company’s financial situation into account, it imposed 500,000 EUR; LocalBitcoins has appealed to the Helsinki Administrative Court.

What organisations can take from it

KYC is a prerequisite for every business relationship – not an obligation to be met retrospectively once volumes grow.

Relevance to training and awareness

Customer identification (KYC)

Authority / court
Finanssivalvonta (FIN-FSA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Finnisches Geldwäschegesetz – Identifizierung und Verifizierung von Kunden
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
3 Jun 2025

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

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2 Jun 2025 HRA Group HoldingsFINTRAC: CAD 132,000 penalty on HRA Group Holdings for 4 violations of anti-money laundering obligations CanadaInternal controls €84,383

According to FINTRAC, HRA Group Holdings is a dealer in precious metals and stones based in Vancouver, British Columbia. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 132,000 on the company on 2 June 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 4 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the compliance training programme and the prescribed review of the compliance programme. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on HRA Group Holdings", published 2 October 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-10-02-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 9.6(1); PCMLTF Regulations 156(1)(b), 156(1)(c), 156(1)(d), 156(1)(e), 156(1)(f); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Published
2 Oct 2025

Original amount 132,000 CAD, converted at the ECB reference rate of 2 Jun 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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29 May 2025 Immobilienmakler aus Calgary, Alberta (anonymisiert)FINTRAC: CAD 117,975 penalty on Calgary real estate brokerage – CAD 63,987.50 paid after appeal was resolved CanadaCustomer due diligence €41,033

According to FINTRAC, the company concerned is a real estate brokerage based in Calgary, Alberta; its name is not given here. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 117,975 on the company on 29 May 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 5 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the compliance training programme, the prescribed review of the compliance programme and record keeping. According to FINTRAC, the policies were a generic template not tailored to the business; the account number was missing in all ten receipt of funds records reviewed. FINTRAC originally set the penalty at CAD 117,975. According to the regulator, the company appealed to the Federal Court; on 28 February 2026 the appeal was resolved, the company paid CAD 63,987.50 and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
PCMLTFA s. 6, 9.6(1); PCMLTF Regulations 58(1)(a), 156(1)(b), 156(1)(c), 156(1)(d), 156(1)(e), 156(1)(f); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
reduced
Sector
Construction and real estate
Published
20 Nov 2025

Original amount 63,987.5 CAD, converted at the ECB reference rate of 29 May 2025.

Checked against the official source on 28 Sep 2026 · Version 4 · Direct link

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21 May 2025 HomeLife New World Realty Inc.FINTRAC: CAD 36,135 penalty on HomeLife New World Realty Inc. for 3 violations of anti-money laundering obligations CanadaCustomer due diligence €22,985

According to FINTRAC, HomeLife New World Realty Inc. is a real estate brokerage based in Toronto and Richmond Hill, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 36,135 on the company on 21 May 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 3 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks and record keeping. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on HomeLife New World Realty Inc.", published 20 November 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-11-20-4-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
PCMLTFA s. 6, 9.6(1); PCMLTF Regulations 58(1)(a), 58(1)(b), 156(1)(b), 156(1)(c), 156(2); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Published
20 Nov 2025

Original amount 36,135 CAD, converted at the ECB reference rate of 21 May 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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20 May 2025 Wechselstube (anonymisiert)CBUAE fines exchange house AED 200m over serious AML failings United Arab EmiratesInternal controls €48.4m

The Central Bank of the UAE (CBUAE) fined an unnamed exchange house AED 200 million under Article 137 of the central bank law (Decretal Federal Law No. 14 of 2018). CBUAE examinations had found significant failures in the company's framework for combating money laundering and the financing of terrorism and illegal organisations.

What organisations can take from it

Weaknesses in an anti-money laundering framework can trigger very large fines.

Relevance to training and awareness

AML frameworks at exchange houses

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 137 Decretal Federal Law No. (14) of 2018 Regarding the Central Bank and Organization of Financial Institutions and Activities
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
20 May 2025

Original amount 200,000,000 AED, converted at the ECB reference rate of 20 May 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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19 May 2025 Alipay (Europe) Limited S.A.Alipay (Europe): EUR 214,000 for failing to file money laundering reports LuxembourgSuspicious activity reports €214,000

The CSSF fined the electronic money institution EUR 214,000. Its inspection from June 2023 to January 2024 found that in six cases of suspected money laundering linked to counterfeit goods no report was made to the Financial Intelligence Unit, in some cases despite the accounts being closed. Transaction monitoring alerts and sanctions screening hits were also handled too slowly or inadequately.

What organisations can take from it

Closing a suspicious account does not end the reporting duty – the suspicion must go to the FIU without delay.

Relevance to training and awareness

Suspicious activity reporting for counterfeit goods trading through payment accounts

Authority / court
Commission de Surveillance du Secteur Financier (CSSF)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Art. 2-1(1) i. V. m. Art. 8-4(1)-(3) Loi modifiée du 12 novembre 2004 (LBC/FT); verletzt u. a. Art. 5(1)(a); Art. 39(5) Règlement CSSF 12-02
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The institution accepted the findings, cooperated fully and informed the CSSF of the remedial measures taken.
Published
2 Sep 2025

Checked against the official source on 2 Oct 2026 · Direct link

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15 May 2025 Primary Capital Inc.FINTRAC: CAD 93,390 penalty on Primary Capital Inc. for 4 violations of anti-money laundering obligations CanadaCustomer due diligence €59,693

According to FINTRAC, Primary Capital Inc. is a securities dealer or wealth management firm based in Toronto, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 93,390 on the company on 15 May 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 4 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the prescribed review of the compliance programme and determining politically exposed persons. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Primary Capital Inc.", published 18 September 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-09-18-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
PCMLTFA s. 9.3(1), 9.6(2); PCMLTF Regulations 119(1), 156(1)(b), 156(1)(c), 156(1)(f), 156(2), 156(3); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
18 Sep 2025

Original amount 93,390 CAD, converted at the ECB reference rate of 15 May 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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14 May 2025 Canaccord Genuity Corp.FINTRAC: CAD 544,500 penalty on Canaccord Genuity Corp. for 4 violations of anti-money laundering obligations CanadaSuspicious activity reports €348,324

According to FINTRAC, Canaccord Genuity Corp. is a securities dealer or wealth management firm based in Vancouver, British Columbia. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 544,500 on the company on 14 May 2025. According to FINTRAC's findings, made during a compliance examination in 2023, the company committed 4 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks and enhanced measures for high-risk situations. Specifically, FINTRAC found three missing suspicious transaction reports in 100 case files reviewed; in 14 files of high-risk clients reviewed, beneficial ownership and client information had not been updated. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Canaccord Genuity Corp.", published 3 July 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-07-03-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9.6(2), 9.6(3); PCMLTF Regulations 156(1)(b), 156(1)(c), 156(2); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
3 Jul 2025

Original amount 544,500 CAD, converted at the ECB reference rate of 14 May 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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8 May 2025 Spence Diamonds Ltd.FINTRAC: CAD 264,000 penalty on Spence Diamonds Ltd. for 5 violations of anti-money laundering obligations CanadaSuspicious activity reports €168,217

According to FINTRAC, Spence Diamonds Ltd. is a dealer in precious metals and stones. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 264,000 on the company on 8 May 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 5 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the compliance training programme and the prescribed review of the compliance programme. Specifically, according to FINTRAC, one suspicious transaction report was missing; the company could also not demonstrate that all employees had been trained or that its compliance programme had been reviewed. According to FINTRAC, the company is paying the penalty in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Spence Diamonds Ltd.", published 23 September 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-09-23-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9.6(1); PCMLTF Regulations 156(1)(b), 156(1)(c), 156(1)(d), 156(1)(e), 156(1)(f); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Published
23 Sep 2025

Original amount 264,000 CAD, converted at the ECB reference rate of 8 May 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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8 May 2025 Ninety One Fund Managers SA (RF) (Pty) LtdFSCA: allegedly ZAR 3m against Ninety One Fund Managers over flaws in its anti-money laundering programme South AfricaInternal controls €146,313

An inspection in September 2023 showed that the fund manager had not effectively implemented its risk management and compliance programme, particularly the risk rating of clients, and had not adequately identified and monitored some clients and beneficial owners on an ongoing basis. In November 2024 the FSCA allegedly imposed a penalty of ZAR 3m, a remediation directive and a caution; following a settlement confirmed by the FIC Act Appeal Board in April 2025, the appeal was withdrawn and ZAR 500,000 was conditionally suspended for three years. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

A written anti-money laundering programme is not enough if client risk rating is not carried out in line with it in day-to-day practice.

Relevance to training and awareness

Risk rating of clients and beneficial owners

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 21, 21B, 21C, 42(1), 42(2); Vergleich nach s. 45D(7)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Remedial action; ZAR 500,000 conditionally suspended.
Published
8 May 2025

Original amount 3,000,000 ZAR, converted at the ECB reference rate of 8 May 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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7 May 2025 Spreadex LimitedSpreadex: £2.02m fine for anti-money laundering and player protection breaches United KingdomInternal controls €2.38m

The Gambling Commission imposed a financial penalty of £2,022,000, a warning and an additional licence condition on the betting operator. Between September 2022 and November 2023 the company breached the anti-money laundering licence condition LC 12.1.1, a customer interaction requirement (SRCP 3.4.3 para. 9c) and a specific condition of its licence; it had also not sufficiently considered the AML guidance in OCP 2.1.1. The Commission had already announced a payment by Spreadex in August 2022.

What organisations can take from it

Specific licence conditions from earlier cases must be demonstrably met; breaching them aggravates the consequences.

Relevance to training and awareness

Complying with specific licence conditions imposed after earlier cases

Authority / court
Gambling Commission
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
LC 12.1.1 Abs. 1–3, SRCP 3.4.3 Abs. 9c, besondere Lizenzauflage und OCP 2.1.1 der Licence Conditions and Codes of Practice (LCCP); s. 117(1)(a) und (b) Gambling Act 2005
Action
Fine
Status of proceedings
unknown
Sector
Other
Repeat case
yes
Mitigating circumstances
The company cooperated throughout the investigation.
Published
15 May 2025

Original amount 2,022,000 GBP, converted at the ECB reference rate of 7 May 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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5 May 2025 Spooniker LtdSpooniker (Unibet and others): warning and SEK 10m for repeated AML failings SwedenCustomer due diligence €914,453

Spelinspektionen (Swedish Gambling Authority) issued the gambling operator Spooniker Ltd (licensed for sites including unibet.se, mariacasino.se and bingo.se) a warning and an administrative fine of 10,000,000 SEK. A follow-up review covering May 2023 to April 2024 again found that, for the five new customers with the highest deposits, the company had not established the source of funds sufficiently or in good time; several of these customers were able to keep depositing even though the deposits could not plausibly have been financed from their known annual taxable income. The authority considered the breaches serious and repeated (earlier decision of 17 November 2022); the Förvaltningsrätten (Administrative Court) in Linköping dismissed the appeal on 2 July 2026, and the judgment is final.

What organisations can take from it

Gambling operators must continuously check the source of funds for large deposits; failing to fully remedy earlier supervisory findings risks tougher sanctions.

Relevance to training and awareness

Source-of-funds checks for large deposits in online gambling

Authority / court
Spelinspektionen
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
3 kap. 1, 13 och 16 §§ samt 4 kap. 1 och 2 §§ lagen (2017:630) om åtgärder mot penningtvätt och finansiering av terrorism; 18 kap. 17–19 §§ spellagen (2018:1138)
Action
Fine
Status of proceedings
final
Sector
Other
Repeat case
yes
Published
6 May 2025

Original amount 10,000,000 SEK, converted at the ECB reference rate of 5 May 2025.

Checked against the official source on 28 Sep 2026 · Direct link

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1 May 2025 MBK Auditing L.L.CFSRA (ADGM): allegedly USD 14,080 on audit firm MBK Auditing for AML failings United Arab EmiratesCustomer due diligence €12,380

From September 2022 to November 2023 the audit firm registered in ADGM, subject to AML duties as a DNFBP, lacked an adequate business risk assessment, did not sufficiently examine customers' ownership structures and businesses, omitted a customer risk assessment in one case and did not appoint a new MLRO in time. After a 20% discount for early settlement the FSRA allegedly imposed USD 14,080 (otherwise USD 17,600).

What organisations can take from it

Audit firms, as obliged entities, must also maintain their own risk assessment, customer due diligence and an MLRO.

Relevance to training and awareness

AML duties of audit firms as DNFBPs

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Section 232 Financial Services and Markets Regulations 2015 (ADGM); AML Rules 6.1.1, 7.1.1, 8.3.1, 8.3.2, 12.1.1 (ADGM AML Rules)
Action
Fine
Status of proceedings
final
Sector
Other
Mitigating circumstances
Early settlement (20% discount), full cooperation and substantial remediation.

Original amount 14,080 USD, converted at the ECB reference rate of 30 Apr 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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28 Apr 2025 Qian DuoDuo LimitedQian DuoDuo: 1,125,000 NZD – transfers of over 19 million NZD not reported New ZealandSuspicious activity reports €589,190

Between June 2018 and September 2019 the Auckland money remitter and foreign exchange provider (trading as Lidong Foreign Exchange) failed to report 197 transfers to China totalling more than 19.14 million NZD: 26 suspicious activities (4.72 million NZD) and 171 prescribed transactions (14.42 million NZD); it checked the source of funds of the two individuals through whom the transactions were conducted only on the basis of questionable documents. On 28 April 2025 the Auckland District Court imposed a fine of 1,125,000 NZD. The company has appealed the decision. The decision is not final.

What organisations can take from it

Suspicious activity reports and prescribed transaction reports are subject to deadlines – failing to verify the source of funds robustly risks penalties running into millions.

Relevance to training and awareness

Suspicious activity reporting and source-of-funds checks

Authority / court
Auckland District Court (Anklage: Department of Internal Affairs)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
AML/CFT Act 2009, ss 48A(1), 97 (Meldung vorgeschriebener Transaktionen) und s 92(1)(b)(i) (Verdachtsmeldung)
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Culpability
intentional
Liability of senior managers
Measures against individuals are not set out here.
Published
5 Jun 2025

Original amount 1,125,000 NZD, converted at the ECB reference rate of 28 Apr 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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25 Apr 2025 Absa Bank LimitedPA: ZAR 10m against Absa over deficient checks on politically exposed clients South AfricaCustomer due diligence €468,147

Following an inspection in 2022, the supervisor objected to inadequate customer due diligence and enhanced due diligence on foreign and domestic politically exposed clients, and to more than 8,500 monitoring alerts not handled within 48 hours. It imposed two cautions, a reprimand and financial penalties of ZAR 10m (7m for customer due diligence, 3m for breaches of Directive 5). The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Politically exposed clients require documented enhanced due diligence, even where only a few files are concerned.

Relevance to training and awareness

Enhanced due diligence on politically exposed persons

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 21(1), 21A; FIC Directive 5 of 2019; Regulation 24(3)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
The bank's cooperation and remedial action.
Published
25 Apr 2025

Original amount 10,000,000 ZAR, converted at the ECB reference rate of 25 Apr 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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24 Apr 2025 Achmea Real Estate B.V. (Nachfolgerin der Syntrus Achmea Real Estate & Finance B.V.)AFM: €1.7m fines for Achmea Real Estate over late money laundering reports NetherlandsSuspicious activity reports €1.7m

On 24 April 2025 the Autoriteit Financiële Markten (AFM, Dutch Authority for the Financial Markets) imposed two fines totalling 1.7 million EUR under the Wwft (Dutch Anti-Money Laundering and Anti-Terrorist Financing Act) on Achmea Real Estate B.V. as successor to Syntrus Achmea Real Estate & Finance B.V. (SAREF). As manager of investment funds, SAREF had reported eleven unusual transactions in its mortgage business late to the FIU between 2018 and 2022 and had not adequately monitored customers and their transactions on an ongoing basis, despite warning signs such as mortgage fraud, a money laundering conviction and unexplained high repayments. In the simplified procedure the company acknowledged the breaches; the fines, originally 1 million EUR each, were reduced by 15% to 850,000 EUR each.

What organisations can take from it

Warning signs in ongoing customer relationships must promptly trigger a review and, where necessary, an immediate report to the FIU.

Relevance to training and awareness

Ongoing monitoring and immediate reporting of unusual transactions

Authority / court
Autoriteit Financiële Markten (AFM)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Art. 1a Abs. 6 i. V. m. Art. 3 Abs. 2 Buchst. d und Art. 16 Abs. 1 Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Acknowledgement of the breaches in the simplified procedure (−15%); improvement programme after the shortcomings came to light.
Published
29 Apr 2025

Checked against the official source on 2 Oct 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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1 Apr 2025 OKCoin Europe LimitedMalta: 1.05 million EUR against crypto exchange OKCoin Europe over anti-money laundering deficiencies MaltaInternal controls €1.05m

During an on-site examination in 2023, the Financial Intelligence Analysis Unit (FIAU) found deficiencies at the crypto service provider in its business risk assessment (including product risks), customer risk assessment, customer profiles, ongoing monitoring, suspicious transaction reporting and record-keeping. It imposed 1,054,269 EUR and a follow-up directive; the fine was open to appeal at the time of publication.

What organisations can take from it

Crypto providers are held to the same due diligence standards as banks – the risk assessment must cover their own products.

Relevance to training and awareness

Anti-money laundering for crypto-assets

Authority / court
Financial Intelligence Analysis Unit (FIAU)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Reg. 5(1), 5(4), 5(5), 7, 11, 15(3), 21 PMLFTR; FIAU Implementing Procedures
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
3 Apr 2025

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

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27 Mar 2025 Coca-Cola Beverages South Africa (Pty) LtdCoca-Cola Beverages South Africa: fine for failing to register with the FIC South AfricaMoney laundering and terrorist financing €1,269

After Schedule 1 of the FIC Act was extended with effect from 19 December 2022 to include, among others, credit providers, the company should have registered with the Financial Intelligence Centre as an accountable institution within 90 days but failed to do so. A fine of 25,000 ZAR was allegedly imposed, reduced to 10,000 ZAR if the company registered by 1 April 2025 and paid by 10 April 2025; the company accepted the sanction on 27 March 2025.

What organisations can take from it

Manufacturing and trading companies that extend credit to customers may also be subject to anti-money laundering duties – check registration requirements after changes in the law.

Relevance to training and awareness

Anti-money laundering duties for non-financial companies extending customer credit

Authority / court
Financial Intelligence Centre (FIC)
Area of law
Money laundering and terrorist financing
Legal basis
Section 43B(1) Financial Intelligence Centre Act 38 of 2001 i. V. m. Regulation 27A(2) Money Laundering and Terrorist Financing Control Regulations; Sanktion nach Section 45C(3)(e) FIC Act
Action
Fine
Status of proceedings
final
Sector
Food and agriculture
Mitigating circumstances
Reduction to 10,000 ZAR for timely registration and payment.

Original amount 25,000 ZAR, converted at the ECB reference rate of 27 Mar 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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21 Mar 2025 Hub Capital Inc.FINTRAC: CAD 99,000 penalty on Hub Capital Inc. for 4 violations of anti-money laundering obligations CanadaInternal controls €63,662

According to FINTRAC, Hub Capital Inc. is a securities dealer or wealth management firm based in Woodbridge, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 99,000 on the company on 21 March 2025. According to FINTRAC's findings, made during a compliance examination in 2023, the company committed 4 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the compliance training programme and the prescribed review of the compliance programme. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Hub Capital Inc.", published 12 June 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-06-12-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 9.6(2); PCMLTF Regulations 156(1)(b), 156(1)(c), 156(1)(d), 156(1)(e), 156(1)(f), 156(2), 156(3); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
12 Jun 2025

Original amount 99,000 CAD, converted at the ECB reference rate of 21 Mar 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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18 Mar 2025 NZForex LimitedNZForex: formal warning over 3,182 unreported transactions New ZealandMoney laundering and terrorist financing Reprimand or warning

The company disclosed to the DIA (Department of Internal Affairs, New Zealand's AML/CFT supervisor) that, because of a system error in its prescribed transaction reporting, 3,182 transactions not denominated in New Zealand dollars had not been reported to the Police Financial Intelligence Unit between November 2017 and February 2024. On 18 March 2025 the DIA issued a formal warning under the AML/CFT Act 2009 and, given the prompt voluntary disclosure, refrained from more serious action; NZForex must provide the final report of an independent audit and report on its remediation.

What organisations can take from it

Reporting processes for prescribed transactions need regular reconciliation so that system errors do not go unnoticed for years; early self-reporting can substantially reduce the sanction.

Relevance to training and awareness

Complete reporting of prescribed transactions to the FIU

Authority / court
Department of Internal Affairs (DIA)
Area of law
Money laundering and terrorist financing
Legal basis
Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (Meldung vorgeschriebener Transaktionen)
Action
Reprimand or warning
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Prompt voluntary disclosure, admission of fault, fixing the system error, reporting all outstanding transactions and a voluntary independent audit.
Published
18 Mar 2025

Checked against the official source on 3 Oct 2026 · Direct link

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17 Mar 2025 Sparebank 1 ØstlandetSparebank 1 Østlandet: NOK 30m for anti-money laundering failures NorwayInternal controls €2.6m

Finanstilsynet (Norwegian Financial Supervisory Authority) fined Sparebank 1 Østlandet NOK 30,000,000 under the Anti-Money Laundering Act after an inspection in September 2022 revealed fundamental shortcomings in risk assessment, procedures, customer risk classification, customer due diligence and ongoing monitoring, as well as a breach of the tipping-off prohibition; the authority classed the breaches as serious and long-standing. It also found that staff training had been inadequate and ordered the bank to complete due diligence measures for one customer. The bank appealed on 8 May 2025. The decision is not final.

What organisations can take from it

Risk-based anti-money laundering compliance stands or falls with an up-to-date risk assessment and role-specific training tailored to the firm's own procedures.

Relevance to training and awareness

Risk-based anti-money laundering controls and role-specific training

Missing or inadequate training played a role in the decision.

Authority / court
Finanstilsynet
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
§§ 6, 7, 8, 9, 12, 13, 14, 17, 18, 24, 25, 28 und 49 hvitvaskingsloven; § 47 hvitvaskingsloven (Anordnung)
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Culpability
negligent
Published
26 Mar 2025

Original amount 30,000,000 NOK, converted at the ECB reference rate of 17 Mar 2025.

Checked against the official source on 28 Sep 2026 · Direct link

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11 Mar 2025 Mooney S.p.A.Banca d'Italia fines Mooney €2.5m for anti-money laundering failings ItalyInternal controls €2.5m

The Banca d'Italia (Bank of Italy) imposed a fine of 2,500,000 EUR on Mooney S.p.A. under Art. 62 of Legislative Decree 231/2007. An on-site inspection from 23 October 2023 to 26 January 2024 had found shortcomings in organisation and internal controls relating to customer profiling, customer due diligence and suspicious transaction reporting, as well as unreported suspicious transactions. In setting the amount, the authority took into account the seriousness of the breaches, the company's turnover and the remedial action it had begun.

What organisations can take from it

Firms that do not embed customer profiling, due diligence and suspicious transaction reporting in robust processes and controls risk fines running into millions, even if they remedy the gaps later.

Relevance to training and awareness

Suspicious transaction reporting and risk-based customer due diligence

Authority / court
Banca d'Italia
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 7, 16–20, 24, 25, 35, 36 und 62 D.Lgs. 231/2007; Bestimmungen der Banca d'Italia vom 26.03.2019 und 30.07.2019; Art. 145 TUB i. V. m. Art. 65 D.Lgs. 231/2007
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The Banca d'Italia took the remedial action already initiated into account.
Liability of senior managers
Measures against individuals are not reported here.
Published
27 May 2025

Checked against the official source on 28 Sep 2026 · Direct link

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5 Mar 2025 Crystal Currency Exchange Inc.FINTRAC: CAD 348,067.50 penalty on Crystal Currency Exchange Inc. for 9 violations of anti-money laundering obligations CanadaSuspicious activity reports €226,047

According to FINTRAC, Crystal Currency Exchange Inc. is a money services business based in Burnaby, British Columbia. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 348,067.50 on the company on 5 March 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 9 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, large cash transaction reporting, international electronic funds transfer reporting, appointing a compliance officer, written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the compliance training programme and the prescribed review of the compliance programme. Specifically, FINTRAC found three missing suspicious transaction reports and several unreported series of cash receipts and incoming and outgoing international transfers that together reached at least CAD 10,000 within 24 hours. According to FINTRAC, the company has appealed the decision to the Federal Court. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Crystal Currency Exchange Inc.", published 29 May 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-05-29-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9.6(1); PCMLTF Regulations 30(1)(a), 30(1)(b), 30(1)(c), 156(1)(a), 156(1)(b), 156(1)(c), 156(1)(d), 156(1)(e), 156(1)(f), 156(3); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
29 May 2025

Original amount 348,067.5 CAD, converted at the ECB reference rate of 5 Mar 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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4 Mar 2025 MAKI podjetje za turizem, trgovino in storitve d.o.o. KoperBureau de change MAKI: transaction limit of 1,000 EUR over unresolved anti-money laundering deficiencies SloveniaInternal controls Order

During a follow-up inspection, Banka Slovenije (Bank of Slovenia) found that the company had not remedied the anti-money laundering deficiencies it had been ordered to address in 2023; some infringements are considered serious. It limited transactions to 1,000 EUR per customer per day, ordered monthly reports and set a deadline of 30 June 2025.

What organisations can take from it

Supervisory orders that are not implemented lead to business restrictions – working through them requires responsible persons and deadline control.

Relevance to training and awareness

Anti-money laundering in small financial service providers

Authority / court
Banka Slovenije
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 164 ZPPDFT-2, Art. 280 ZBan-3, Art. 42.a ZBS-1
Action
Order
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes

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

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3 Mar 2025 Cambrian Credit UnionFINTRAC: CAD 116,160 penalty on Cambrian Credit Union for 4 violations of anti-money laundering obligations CanadaSuspicious activity reports €76,907

According to FINTRAC, Cambrian Credit Union is a credit union based in Winnipeg, Manitoba. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 116,160 on the company on 3 March 2025. According to FINTRAC's findings, made during a compliance examination in 2023, the company committed 4 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, international electronic funds transfer reporting, written compliance policies and procedures and assessing and documenting money laundering and terrorist financing risks. Specifically, according to FINTRAC, one suspicious transaction report and two reports of incoming international transfers were missing; policies on ongoing monitoring and the risk assessment were insufficiently documented. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Cambrian Credit Union", published 10 June 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-06-10-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7; PCMLTF Regulations 7(1)(c), 156(1)(b), 156(1)(c), 156(2); PCMLTF Suspicious Transaction Reporting Regulations s. 9(1); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
10 Jun 2025

Original amount 116,160 CAD, converted at the ECB reference rate of 3 Mar 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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27 Feb 2025 Morgan Stanley (Switzerland) GmbHMorgan Stanley (Switzerland): 1 million CHF fine for organisational deficiency in money laundering case SwitzerlandInternal controls €1.06m

In 2010, the company's legal predecessor did not take all necessary and reasonable organisational precautions to prevent a relationship manager from committing aggravated money laundering with assets derived from bribery offences in Greece. The Office of the Attorney General of Switzerland (Bundesanwaltschaft) concluded the proceedings with a summary penalty order of 1 million CHF.

What organisations can take from it

Under corporate criminal law, organisational deficiencies do not become time-barred when the employee leaves – controls must be demonstrably effective.

Authority / court
Bundesanwaltschaft
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 102 Abs. 2 StGB i. V. m. Art. 305bis StGB
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
27 Feb 2025

Original amount 1,000,000 CHF, converted at the ECB reference rate of 27 Feb 2025.

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

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27 Feb 2025 Emirates Advocates LLPADGM: law firm Emirates Advocates loses AML registration after years without AML returns United Arab EmiratesInternal controls Order

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) withdrew, with effect from 27 February 2025, the law firm's registration as a designated non-financial business or profession (DNFBP) for anti-money laundering purposes, which it needs to operate in ADGM. The firm had not filed its annual AML returns for 2019 to 2023 and, in the regulator's view, lacked adequate systems and controls; fines had already been imposed in 2021 (10,000 USD for the missing 2019 return) and in 2023 (26,000 USD for the missing goAML registration). The Decision Notice of 21 January 2025 was not referred to the Appeals Panel.

What organisations can take from it

A law firm that persistently ignores its anti-money laundering duties risks not only fines but also its registration, and with it its business in the financial centre.

Relevance to training and awareness

Anti-money laundering duties for law firms and other DNFBPs

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Section 251 FSMR 2015; AML Rules 4.6.1, 15.2.1(1)(b), 15.7.1(2)(c), 15.7.2(1)(a) und (b)
Action
Order
Status of proceedings
final
Sector
Other
Repeat case
yes

Checked against the official source on 3 Oct 2026 · Direct link

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19 Feb 2025 Wechselstube (anonymisiert, Sanktion vom 19.02.2025)CBUAE: AED 3.5m on an exchange house for AML breaches United Arab EmiratesInternal controls €913,388

Following an examination, the Central Bank found that an unnamed exchange house had not complied with its policies and procedures for combating money laundering and terrorist financing. The CBUAE imposed a financial sanction of AED 3.5 million.

What organisations can take from it

Exchange houses are under close AML supervision – gaps between policy and practice are punished with sums in the millions.

Relevance to training and awareness

AML prevention in exchange houses

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 14 Federal Decree Law No. (20) of 2018 on AML/CFT
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
19 Feb 2025

Original amount 3,500,000 AED, converted at the ECB reference rate of 19 Feb 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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17 Feb 2025 Mako Financial Markets Partnership LLPFCA: £1.66m fine for Mako over control failings in OTC equity trading United KingdomInternal controls €2m

The FCA fined Mako Financial Markets Partnership LLP £1,662,700, of which £1,137,283 is disgorgement. The FCA found that between December 2013 and November 2015 Mako executed over-the-counter trades for clients introduced by another broker group, without adequate systems and controls against fraud and money laundering. Customer due diligence and transaction monitoring were, in the FCA's view, inadequate, and red flags in certain equity trades were missed. The fine includes a settlement discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
FCA Principles 2 und 3; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 1,662,700 GBP, converted at the ECB reference rate of 17 Feb 2025.

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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4 Feb 2025 AG Communications LimitedAG Communications: £1,187,500 over AML, player protection and self-exclusion failings United KingdomInternal controls €1.43m

The online operator will pay £1,187,500 in lieu of a financial penalty under a settlement and contribute to the Commission's investigation costs. The settlement also includes a divestment of £220,334, which is not included in the amount shown. A compliance assessment found breaches between May 2023 and October 2024 of the anti-money laundering licence condition LC 12.1.1 para. 3 and of requirements on customer interaction, customer identification, information to customers, reporting of key events and display of rules; the self-exclusion requirements were breached from October 2022 to May 2024, so that, for example, one self-excluded customer was able to set up more than 100 accounts. The Commission had already announced a fine against the company in 2022.

What organisations can take from it

Self-exclusions and loss limits must be enforced as technically binding, not merely offered.

Relevance to training and awareness

Technical enforcement of self-exclusion and loss limits

Authority / court
Gambling Commission
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
s. 116 Gambling Act 2005; LC 12.1.1 Abs. 3, SRCP 3.4.3, SRCP 3.9.1, LC 4.2.1, LC 15.2.1, SRCP 4.2.6 und SRCP 3.5.3 der Licence Conditions and Codes of Practice (LCCP)
Action
Fine
Status of proceedings
final
Sector
Other
Repeat case
yes
Mitigating circumstances
An action plan following the December 2023 assessment, full cooperation with regular updates, early acceptance of the failings and a voluntarily agreed external audit on anti-money laundering and safer gambling, including to improve internal training.
Published
4 Mar 2025

Original amount 1,187,500 GBP, converted at the ECB reference rate of 4 Feb 2025.

Checked against the official source on 3 Oct 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 USAInternal controls €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.

What organisations can take from it

Anyone moving cash across borders for third parties must check whether this triggers registration and reporting duties as a money services business.

Relevance to training and awareness

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.

Checked against the official source on 3 Oct 2026 · Direct link

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24 Jan 2025 The Standard Bank of South Africa LimitedPA: ZAR 13m against Standard Bank over late reports to the FIC South AfricaSuspicious activity reports €675,255

Following an inspection in 2022, the supervisor found that the bank had filed 17,259 suspicious transaction reports and 1,466 cash transaction reports late and failed to file one suspicious report at all, had not recorded the submission dates of 43 suspicious reports, omitted ongoing due diligence on two clients and not handled some 75,700 monitoring alerts on time. Sanction: six cautions and financial penalties totalling ZAR 13m (4m for late suspicious reports, 1m for the missing report, 8m for breaches of Directive 5). The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Identifying suspicious cases but not reporting them on time breaches the reporting duty just as not reporting at all does; reporting processes need capacity and deadline control.

Relevance to training and awareness

Timely suspicious and cash transaction reporting

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 21C, 23(c), 28, 29; FIC Directive 5 of 2019; Regulation 24(3)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
The bank's cooperation and remedial action.
Published
24 Jan 2025

Original amount 13,000,000 ZAR, converted at the ECB reference rate of 24 Jan 2025.

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22 Jan 2025 BDO Italia S.p.A.CONSOB fines BDO Italia €120,000 over anti-money laundering duties as auditor ItalyCustomer due diligence €120,000

The CONSOB (Italian securities regulator) imposed a fine of 120,000 EUR on the audit firm BDO Italia S.p.A. under Art. 62(5) of Legislative Decree 231/2007. In its audit engagements for a crypto-asset service provider and its parent company, BDO had, between 17 June 2021 and 2 January 2023, inadequately assessed the clients' money laundering risk, failed to apply enhanced due diligence and neglected ongoing monitoring. The Corte d'Appello (Court of Appeal) of Milan dismissed the firm's objection on 29 April 2026.

What organisations can take from it

Auditors are themselves obliged entities under anti-money laundering law and must apply enhanced due diligence and ongoing monitoring to high-risk clients.

Relevance to training and awareness

Anti-money laundering duties of auditors with high-risk clients

Authority / court
CONSOB (Commissione Nazionale per le Società e la Borsa)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 15 Abs. 2, 17 Abs. 3, 19 Abs. 1 lit. d, 24 Abs. 1 und 62 Abs. 5 D.Lgs. 231/2007; Art. 6, 20, 28 und 31 CONSOB-Verordnung Nr. 20570/2018
Action
Fine
Status of proceedings
unknown
Sector
Other
Culpability
negligent
Repeat case
yes
Mitigating circumstances
The CONSOB noted the firm's cooperation, albeit required of it, during the on-site inspection and the adjustments to its internal procedures that it had since begun.
Published
30 Jan 2025
Sources

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15 Jan 2025 Saxony: fine against estate agent for breach of AML due diligence obligations GermanyCustomer due diligence €800

The Saxony State Directorate (Landesdirektion Sachsen), as anti-money laundering supervisor for the non-financial sector, imposed a fine of 800 EUR on an estate agent, announced in anonymised form, for breach of the due diligence obligations under the German Money Laundering Act (GwG). The list of announcements shows numerous further fines and reprimands against agents ranging from 50 to 5,000 EUR.

What organisations can take from it

Estate agents must identify both contracting parties in good time – even small offices are subject to active anti-money laundering supervision.

Relevance to training and awareness

Identification of contracting parties in property brokerage

Authority / court
Landesdirektion Sachsen (Geldwäscheaufsicht Nichtfinanzsektor)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Geldwäschegesetz (Sorgfaltspflichten); Bekanntmachung nach § 57 GwG
Action
Fine
Status of proceedings
final
Sector
Construction and real estate

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

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9 Jan 2025 Greentube Alderney LimitedGreentube Alderney: £977,887 over anti-money laundering and customer interaction failings United KingdomInternal controls €1.17m

The operator of admiralcasino.co.uk will pay £977,887 in lieu of a financial penalty under a settlement and contribute to the Commission's investigation costs. The settlement also includes a divestment of £22,113, which is not included in the amount shown. Between September 2022 and June 2023 it did not implement its money laundering controls effectively – a bank statement submitted as proof of address showing unusual transactions was only scrutinised four months later – and between December 2022 and June 2023 its customer interaction fell short of the requirements. The Commission had already accepted a regulatory settlement from the company in 2021.

What organisations can take from it

Documents received at account opening must be reviewed for money laundering risks immediately, not only when the next threshold is reached.

Relevance to training and awareness

Immediate review of customer documents for money laundering risks

Authority / court
Gambling Commission
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
s. 116 Gambling Act 2005; LC 12.1.1 Abs. 3 und SRCP 3.4.3 Abs. 1 und 8 der Licence Conditions and Codes of Practice (LCCP)
Action
Fine
Status of proceedings
final
Sector
Other
Repeat case
yes
Mitigating circumstances
A swift action plan with progress updates, full cooperation with information provided by agreed deadlines and early acceptance of the failings.
Published
9 Jan 2025

Original amount 977,887 GBP, converted at the ECB reference rate of 9 Jan 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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9 Jan 2025 ein kleiner britischer BrokerFCA: small broker fined over cum-ex money laundering risks United KingdomInternal controls €344,791

From January to September 2015, the broker had no effective systems against financial crime and was therefore exposed to the risk of facilitating fraudulent trading and money laundering in connection with cum-ex trades. Following proceedings before the Upper Tribunal, the UK Financial Conduct Authority (FCA) set the fine at £288,962.53 instead of the £744,745 originally intended.

What organisations can take from it

Even small brokers must question unusually lucrative, circular trading patterns before executing them.

Relevance to training and awareness

Recognising warning signs in unusual trading structures

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
FCA Principles 2 und 3 (PRIN 2, PRIN 3)
Action
Fine
Status of proceedings
reduced
Sector
Financial services and insurance
Employees
Under 50
Mitigating circumstances
Reduction by the Upper Tribunal
Published
10 Jan 2025

Original amount 288,962.53 GBP, converted at the ECB reference rate of 9 Jan 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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26 Dec 2024 株式会社イオン銀行 (AEON Bank, Ltd.)AEON Bank: order over 14,639 unreviewed money laundering alerts JapanSuspicious activity reports Order

Between June and November 2023 and between July and September 2024, the bank failed to assess at least 14,639 transactions flagged by its transaction monitoring for whether suspicious transaction reports were needed, and took up to 152 days on monthly average to file reports (February 2024). It had also not implemented the measures required by the supervisory AML/CFT guidelines by the end-March 2024 deadline and had not remedied findings from the previous inspection. The business improvement order under Art. 26(1) of the Banking Act requires, among other things, the outstanding reviews and reports to be completed and governance by the board and management to be fundamentally strengthened.

What organisations can take from it

Transaction monitoring only works with enough staff to assess every alert promptly; backlogs must reach the board.

Relevance to training and awareness

Prompt handling of monitoring alerts and suspicious transaction reports

Authority / court
Financial Services Agency (FSA, 金融庁)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Banking Act (銀行法) Art. 26 Abs. 1; Act on Prevention of Transfer of Criminal Proceeds (犯罪収益移転防止法); Guidelines for AML/CFT der FSA
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Liability of senior managers
According to the reasons, the board and management neither established the facts themselves nor gave instructions despite repeated signals from backlogs, inspection findings and internal audit; the order requires responsibility to be clarified.
Published
26 Dec 2024

Checked against the official source on 4 Oct 2026 · Direct link

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20 Dec 2024 Argosy Securities Inc.FINTRAC: CAD 66,000 penalty on Argosy Securities Inc. for 3 violations of anti-money laundering obligations CanadaInternal controls €44,159

According to FINTRAC, Argosy Securities Inc. is a securities dealer or wealth management firm based in Richmond Hill, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 66,000 on the company on 20 December 2024. According to FINTRAC's findings, made during a compliance examination, the company committed 3 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks and the prescribed review of the compliance programme. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Argosy Securities Inc.", published 13 February 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-02-13-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTF Regulations 156(1)(b), 156(1)(c), 156(1)(f), 156(2), 156(3); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
13 Feb 2025

Original amount 66,000 CAD, converted at the ECB reference rate of 20 Dec 2024.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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19 Dec 2024 MSBG International Holdings Ltd.FINTRAC: CAD 24,750 penalty on MSBG International Holdings Ltd. for one violation of anti-money laundering obligations CanadaInternal controls €16,577

According to FINTRAC, MSBG International Holdings Ltd. is a money services business based in Vancouver, British Columbia. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 24,750 on the company on 19 December 2024. According to FINTRAC's findings, made during a compliance examination in 2023, the company committed one violation of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violation concerned written compliance policies and procedures. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on MSBG International Holdings Ltd.", published 25 February 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-02-25-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTF Regulations 71(1)(b); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
25 Feb 2025

Original amount 24,750 CAD, converted at the ECB reference rate of 19 Dec 2024.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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16 Dec 2024 Jyske Bank A/SJyske Bank: almost DKK 24m over anti-money-laundering failings in Keyplan Mortgage unit DenmarkCustomer due diligence €3.21m

Jyske Bank accepted a fine notice (bødeforelæg) of 23,961,500 DKK from the National enhed for Særlig Kriminalitet (NSK, Danish National Special Crime Unit). It followed a report by the Finanstilsynet (Danish Financial Supervisory Authority) of November 2022 after an anti-money-laundering inspection of the Keyplan Mortgage unit: the bank had not applied sufficient customer due diligence and enhanced due diligence to customers classified as high-risk, and had not investigated suspicious transactions.

What organisations can take from it

High-risk customers in specialist units need the same enhanced checks and transaction monitoring as in the core business.

Relevance to training and awareness

Enhanced due diligence and transaction review for high-risk customers

Authority / court
National enhed for Særlig Kriminalitet (NSK) auf Anzeige des Finanstilsynet
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Hvidvaskloven § 11 stk. 1 nr. 4 og 5, § 17 stk. 1, § 25 stk. 1
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
16 Dec 2024

Original amount 23,961,500 DKK, converted at the ECB reference rate of 16 Dec 2024.

Checked against the official source on 28 Sep 2026 · Direct link

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13 Dec 2024 Aarna Capital LimitedADGM: allegedly 504,000 USD fine for broker Aarna Capital over KYC and monitoring failures United Arab EmiratesCustomer due diligence €479,179

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the broker for professional clients allegedly 504,000 USD for inadequate anti-money laundering controls between June 2017 and January 2023. In a review of 42 client relationships the regulator found that twelve clients should have been rated high risk because of relevant risk factors, so enhanced due diligence and annual reviews did not take place; documentation, risk-based updating of customer data, transaction monitoring and procedures to detect suspicious activity were also inadequate. The regulator identified no specific instances of money laundering; without the 20% discount for early settlement the fine would have been 630,000 USD.

What organisations can take from it

A risk rating that is too lenient undermines every downstream control, from enhanced due diligence to periodic review.

Relevance to training and awareness

Customer risk rating and ongoing transaction monitoring

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Section 232 FSMR 2015; AML Rules 4.1.1(1), 4.1.1(2)(a) und (d), 4.5.1(b), 4.5.3, 7.1.1, 8.1.2(1), 8.6.1(a), 14.2.1
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
No previous breaches of the AML rules (though earlier action over CRS reporting duties), cooperation and remediation including an external gap analysis (10% reduction); 20% discount for early settlement.

Original amount 504,000 USD, converted at the ECB reference rate of 13 Dec 2024.

Checked against the official source on 3 Oct 2026 · Direct link

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10 Dec 2024 Klarna Bank ABKlarna: SEK 500m for gaps in money laundering risk assessment and procedures SwedenInternal controls €43.4m

Finansinspektionen (FI, Swedish Financial Supervisory Authority) issued Klarna a remark and an administrative fine of 500,000,000 SEK for breaches of the anti-money laundering act between 1 April 2021 and 31 March 2022. The general risk assessment lacked, among other things, assessments of how products and services could be misused for money laundering or terrorist financing; for the invoice product (faktura) there were no procedures capturing all situations requiring due diligence, and there was no procedure for model risk management. The maximum was based on the group's 2023 turnover of 24.64 billion SEK; the bank itself had a turnover of 19.65 billion SEK.

What organisations can take from it

Fast-growing payment providers must reflect every product in their money laundering risk assessment and maintain procedures for every trigger of due diligence obligations.

Relevance to training and awareness

Money laundering risk assessment for payment products and procedures for customer due diligence

Authority / court
Finansinspektionen (FI)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
2 kap. 1 och 8 §§ samt 6 kap. 1 § andra stycket lagen (2017:630) om åtgärder mot penningtvätt och finansiering av terrorism; 15 kap. 1 och 7 §§ lagen (2004:297) om bank- och finansieringsrörelse
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
FI did not treat cooperation, remediation or the proceedings' length of just over two and a half years as mitigating.
Published
11 Dec 2024

Original amount 500,000,000 SEK, converted at the ECB reference rate of 10 Dec 2024.

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6 Dec 2024 China CITIC Bank International LimitedHKMA: HKD 4m fine for China CITIC Bank International over misconfigured rules Hong KongInternal controls €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.

What organisations can take from it

The parameters of a monitoring system belong under maker-checker control and must be tested against the business requirements before going live.

Relevance to training and awareness

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.

Checked against the official source on 3 Oct 2026 · Direct link

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2 Dec 2024 2147353 Ontario Inc.FINTRAC: CAD 33,000 penalty on 2147353 Ontario Inc. for one violation of anti-money laundering obligations CanadaInternal controls €22,376

According to FINTRAC, 2147353 Ontario Inc. is a money services business based in Mississauga, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 33,000 on the company on 2 December 2024. According to FINTRAC's findings, the company committed one violation of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violation concerned providing documents requested by notice. According to FINTRAC, the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "FINTRAC imposes an administrative monetary penalty on Cash Shop #27", published 6 February 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-02-06-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 63.1(2); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
6 Feb 2025

Original amount 33,000 CAD, converted at the ECB reference rate of 2 Dec 2024.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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25 Nov 2024 KT Bank AGBaFin imposes 30 fines totalling €600,000 on KT Bank for AML and banking law breaches GermanyCustomer due diligence €600,000

BaFin (German Federal Financial Supervisory Authority) imposed 30 fines of 20,000 EUR each, 600,000 EUR in total, on KT Bank AG. Among other things, the bank had not effectively monitored its internal safeguards, had not retained identification records, had not continuously monitored business relationships, had not recorded the names of beneficial owners, had failed to file suspicious activity reports and had granted loans without fully reviewing the financial circumstances under the disclosure requirements. The decision of 25 November 2024 has been final since 20 December 2024.

What organisations can take from it

Many gaps in the customer process, from identification to suspicious activity reporting, are fined individually and add up.

Relevance to training and awareness

Identifying beneficial owners and continuously monitoring business relationships

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 56 Abs. 1 Nr. 3, 7, 20, 21, 30, 33 und 69 GwG; § 56 Abs. 2 Nr. 5 KWG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
23 Jan 2025

Checked against the official source on 2 Oct 2026 · Direct link

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21 Nov 2024 Tana Africa Capital Managers (Pty) LtdFSCA: ZAR 2.9m against Tana Africa Capital Managers, upheld by the Appeal Board South AfricaInternal controls €152,404

An inspection showed that the asset manager's risk management and compliance programme was deficient and not effectively implemented, and that client data was not screened against the UN Security Council targeted financial sanctions lists. The FSCA imposed ZAR 2.9m, of which ZAR 1m is conditionally suspended for three years; on 6 November 2024 the FIC Act Appeal Board dismissed the appeal against the amount and held that reliance on an external compliance adviser does not relieve an institution of responsibility. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

A firm that outsources compliance to an external provider remains responsible for meeting its anti-money laundering duties itself, even with just a single client.

Relevance to training and awareness

Sanctions list screening and accountability despite external compliance advice

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 42(1), 42(2) i. V. m. s. 21(1); s. 28A i. V. m. ss. 26A–26C
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
ZAR 1m conditionally suspended for three years.
Published
21 Nov 2024

Original amount 2,900,000 ZAR, converted at the ECB reference rate of 21 Nov 2024.

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20 Nov 2024 Harvey Nichols and Company LtdHarvey Nichols: £175,701 fine for money laundering failings as a high value dealer United KingdomInternal controls €210,723

HMRC imposed a penalty of £175,701 under the Money Laundering Regulations 2017 on the company, which is supervised for anti-money laundering purposes as a high value dealer. The failings concerned risk assessment, policies, controls and procedures, staff training, due diligence and record keeping; no appeal was lodged.

What organisations can take from it

A business registered as a high value dealer needs risk assessment, training and customer checks just like a financial institution.

Relevance to training and awareness

Anti-money laundering duties for high value dealers

Missing or inadequate training played a role in the decision.

Authority / court
HM Revenue & Customs (HMRC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Reg. 18, 19, 24, 28, 35 und 40 Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Published
20 Nov 2024

Original amount 175,701 GBP, converted at the ECB reference rate of 20 Nov 2024.

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20 Nov 2024 Immobilienmakler aus Laval, Québec (anonymisiert)FINTRAC: CAD 107,250 penalty on real estate broker from Laval for 4 violations of anti-money laundering obligations CanadaInternal controls €72,628

According to FINTRAC, the company concerned is a real estate brokerage based in Laval, Quebec; its name is not given here. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 107,250 on the company on 20 November 2024. According to FINTRAC's findings, made during a compliance examination, the company committed 4 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the compliance training programme and the prescribed review of the compliance programme. Specifically, FINTRAC found five gaps in the policies, including on beneficial ownership, third-party determination and politically exposed persons; the risk assessment consisted of a generic form without risk levels or mitigation measures. According to FINTRAC, the company has appealed the decision to the Federal Court. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 9.6(1); PCMLTF Regulations 156(1)(b), 156(1)(c), 156(1)(e), 156(1)(f), 156(2), 156(3); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Construction and real estate
Published
1 May 2025

Original amount 107,250 CAD, converted at the ECB reference rate of 20 Nov 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Direct link

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13 Nov 2024 Integritas Consulting LtdMalta: 66,504 EUR against corporate services firm Integritas for lack of monitoring MaltaCustomer due diligence €66,504

The corporate services provider did not question why a client company that had been dormant for seven years suddenly received over 4 million EUR and passed almost identical amounts on to its shareholder, and did not keep customer information up to date. The Financial Intelligence Analysis Unit (FIAU) imposed 66,504 EUR; remediation was no longer possible because the firm had surrendered its licence and is being wound up.

What organisations can take from it

Sudden flows of millions through dormant companies are a trigger for updated due diligence and, where appropriate, a suspicious transaction report.

Relevance to training and awareness

Recognising unusual transactions in dormant companies

Authority / court
Financial Intelligence Analysis Unit (FIAU)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Reg. 7(2)(a), 7(2)(b), 11(9), 15(3) PMLFTR
Action
Fine
Status of proceedings
unknown
Sector
Other
Published
13 Nov 2024

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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12 Nov 2024 Metro Bank PlcFCA: £16.7m fine for Metro Bank over gaps in transaction monitoring United KingdomInternal controls €20.1m

The FCA fined Metro Bank Plc £16,675,200. The FCA found that between June 2016 and December 2020 a data error meant that more than 60 million transactions worth over £51 billion were not fed into the bank's automated anti-money laundering monitoring system. For a long time the bank did not check whether data reached the system completely. The fine includes a 30% settlement discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
FCA Principle 3; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 16,675,200 GBP, converted at the ECB reference rate of 12 Nov 2024.

Checked against the official source on 28 Sep 2026 · Version 2 · 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 Hong KongInternal controls €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.

What organisations can take from it

A sudden fall in monitoring alerts is itself a warning sign and must be investigated after every system change.

Relevance to training and awareness

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.

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5 Nov 2024 Exchange Bank of CanadaFINTRAC: penalty on Exchange Bank of Canada reduced to CAD 1,027,975 on appeal CanadaSuspicious activity reports €679,518

According to FINTRAC, Exchange Bank of Canada is a bank based in Toronto, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 2,457,750 on the company on 5 November 2024. According to FINTRAC's findings, made during a compliance examination, the company committed 3 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, ongoing monitoring of business relationships and large cash transaction reporting. Specifically, FINTRAC found five missing suspicious transaction reports in 26 case files reviewed, eight cases without the required ongoing monitoring and three misclassified and therefore unreported cash transactions; the compliance programme had not been adequate for the bank's business model and global reach. The bank filed an appeal; according to FINTRAC, the Federal Court confirmed the violations on 18 December 2025 but varied the penalty to CAD 1,027,975. The case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Exchange Bank of Canada", published 11 December 2024, https://fintrac-canafe.canada.ca/pen/amps/pen-2024-12-11-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9(1); PCMLTF Regulations 7(1)(a), 123.1, 156(1)(c), Schedule 1; PCMLTF Suspicious Transaction Reporting Regulations s. 9(1); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
reduced
Sector
Financial services and insurance
Published
11 Dec 2024

Original amount 1,027,975 CAD, converted at the ECB reference rate of 5 Nov 2024.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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5 Nov 2024 Edmond de Rothschild Assurances et Conseils (Europe) S.A.Edmond de Rothschild Assurances et Conseils (Europe): EUR 61,000 for AML failings LuxembourgInternal controls €61,000

The Commissariat aux Assurances (CAA, Luxembourg insurance supervisor) fined the insurance brokerage EUR 61,000. A 2021 inspection found, among other things, an inadequate outsourcing contract with the parent company, an incomplete overall risk assessment, gaps on beneficial owners, source of funds and PEPs, a screening tool whose configuration could not be explained and missing annual reports by the compliance officer. The company was also unable to give access to the materials of its internal anti-money laundering training.

What organisations can take from it

Training only counts if its content is documented and can be shown to the supervisor; outsourced due diligence needs a precise contract.

Relevance to training and awareness

Demonstrable anti-money laundering training and outsourcing of due diligence

Missing or inadequate training played a role in the decision.

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 2-1(2), 8-4 und 8-5 Loi modifiée du 12 novembre 2004 (LBC/FT); Règlement grand-ducal du 1er février 2010; Règlement CAA 20/03
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Close cooperation with the CAA during and after the inspection, with timely replies.
Published
15 Jan 2025

Checked against the official source on 2 Oct 2026 · Direct link

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4 Nov 2024 Money Services Business aus Toronto, Ontario (anonymisiert)FINTRAC: CAD 249,480.50 penalty on money services business from Toronto for 6 violations of anti-money laundering obligations CanadaCustomer due diligence €164,619

According to FINTRAC, the company concerned is a money services business based in Toronto, Ontario; its name is not given here. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 249,480.50 on the company on 4 November 2024. According to FINTRAC's findings, made during a compliance examination in 2023, the company committed 6 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, compliance with a ministerial directive, record keeping and money services business registration requirements. Specifically, contrary to the ministerial directive on Iran, the company failed to report 44 transactions originating from Iran, recorded neither the exchange rate nor its source for these foreign exchange transactions and provided registration details that did not reflect its actual activities. According to FINTRAC, the company has appealed the decision to the Federal Court. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
PCMLTFA s. 9.6(1), 11.43; PCMLTF Regulations 36(i), 156(1)(b), 156(1)(c); PCMLTF Registration Regulations s. 4(a), 4(b), 5; Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
13 May 2025

Original amount 249,480.5 CAD, converted at the ECB reference rate of 4 Nov 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Direct link

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29 Oct 2024 Raiffeisenbank Austria d.d.Croatia: 142,483 EUR fine for Raiffeisenbank Austria over anti-money-laundering breaches CroatiaCustomer due diligence €142,483

On the basis of an agreement with the Hrvatska narodna banka (HNB, Croatian National Bank), the Financijski inspektorat (Financial Inspectorate) issued a penalty decision against Raiffeisenbank Austria d.d.: for several customers the bank had failed to take risk factors into account in due diligence, did not monitor business relationships on an ongoing basis, did not properly establish beneficial owners, and did not analyse unusual cash and transfer patterns or report them to the financial intelligence unit. The bank received fines totalling EUR 142,482.94.

What organisations can take from it

Transaction patterns that do not match declared income must be analysed, documented and reported.

Relevance to training and awareness

Recognising and reporting unusual cash patterns

Authority / court
Ministarstvo financija, Financijski inspektorat (Veröffentlichung durch die Hrvatska narodna banka)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 150 Abs. 1 Nr. 8, 11, 23, 26, 43, 44 Zakon o sprječavanju pranja novca i financiranja terorizma (i. V. m. Art. 14, 15, 30, 37, 53)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
The proceedings were concluded by an agreement between the parties (Art. 109.e of the Misdemeanours Act).
Liability of senior managers
Measures against individuals are not reported here.

Checked against the official source on 28 Sep 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 USASuspicious activity 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.

What organisations can take from it

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.

Relevance to training and awareness

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.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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15 Oct 2024 Fio banka, a.s.ČNB: CZK 9.5m fine for Fio banka over deficient AML and sanctions controls CzechiaInternal controls €376,357

By way of a penalty order (příkaz), the ČNB (Czech National Bank) fined Fio banka 9,500,000 CZK. In 2021 the bank lacked adequate internal procedures for, among other things, screening against sanctions lists, customer risk profiles, due diligence on credit and financial institutions as customers, transaction monitoring (for example whitelisting, deposit machines and politically exposed persons) and lending, and between 2020 and 2022 it failed to examine adequately the ownership structure, risk rating and transactions of a single corporate customer. In addition, from 2019 to May 2022 it did not train certain staff in anti-money laundering within the twelve-month deadline and, by means of an internal list, excluded members of the supervisory board and the head of internal audit from this training altogether.

What organisations can take from it

Sanctions screening and transaction monitoring must capture every party at system level, including pledgors, owners and counterparty banks, otherwise gaps remain despite written policies.

Relevance to training and awareness

Sanctions list screening, transaction monitoring and AML training in banking operations

Missing or inadequate training played a role in the decision.

Authority / court
Česká národní banka (ČNB)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
§ 9 Abs. 1 lit. c, § 21 Abs. 1, § 23 Abs. 1 und 2, § 44 Abs. 1 lit. b und Abs. 2, § 48 Abs. 1 und 6 Zákon č. 253/2008 Sb. (AML-Gesetz)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 9,500,000 CZK, converted at the ECB reference rate of 15 Oct 2024.

Checked against the official source on 28 Sep 2026 · Version 2 · 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 USAInternal controlsanonymised €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.

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 28 Sep 2026 · Version 3 · Company name anonymised since 10 Oct 2026 · Direct link

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27 Sep 2024 a UK digital bankFCA: £29m fine for digital bank over financial crime controls United KingdomCustomer due diligenceanonymised €34.7m

The FCA fined a UK digital bank £28,959,426. The FCA found that the fast-growing bank's controls against money laundering and sanctions breaches did not keep pace with its growth. Although the bank agreed with the FCA in 2021 not to open accounts for high-risk customers, it opened 54,359 accounts for 49,183 such customers. In addition, screening of customers and payments against sanctions lists was inadequate between December 2019 and November 2023. The fine includes a 30% discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
FCA Principle 3; Verstoß gegen freiwillige Auflage (VREQ) nach FSMA 2000; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 28,959,426 GBP, converted at the ECB reference rate of 27 Sep 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 27 Sep 2026 · Direct link

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27 Sep 2024 a South African life insurerLife insurer: ZAR 15.9m for breaches of anti-money laundering duties South AfricaCustomer due diligenceanonymised €832,060

A 2020 inspection found that the life insurer had not carried out adequate customer due diligence on sampled relationships (including address verification and identification of beneficial owners), had reported cash transactions above the threshold and suspicious transactions late, and had not adequately developed and implemented its risk management and compliance programme. Four cautions and penalties totalling 15.9 million ZAR were imposed, of which 5.9 million ZAR is conditionally suspended for 36 months from 23 July 2024.

What organisations can take from it

Life insurers, too, must risk-rate clients before onboarding and meet the reporting deadlines towards the financial intelligence unit.

Relevance to training and awareness

Customer due diligence and reporting deadlines in insurance distribution

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Sections 21, 21A–21H, 28 (i. V. m. Regulations 22B, 22C, 24(4)), 29 (i. V. m. Regulation 24(3)) und 42 Financial Intelligence Centre Act 38 of 2001
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation throughout the process and remedial action; 5.9 million ZAR suspended for 36 months.
Published
27 Sep 2024

Original amount 15,900,000 ZAR, converted at the ECB reference rate of 27 Sep 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 27 Sep 2026 · Direct link

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18 Sep 2024 a Danish major bankPNF: Danish major bank pays €6.33m over laundering the proceeds of tax fraud FranceMoney laundering and terrorist financinganonymised €6.33m

The bank undertook, in a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement) with the Parquet national financier (PNF, French national financial prosecutor), to pay a public interest fine of 6,028,799 EUR and 300,000 EUR in damages to the French State, 6,328,799 EUR in total. The allegation concerned money laundering linked to organised tax fraud; in the same matter, a natural person had already been convicted of money laundering by the Tribunal correctionnel de Paris in January 2024. Validated on 18 September 2024.

What organisations can take from it

Banks face criminal liability when proceeds of organised tax fraud flow through their accounts; customer due diligence and transaction monitoring must capture this.

Relevance to training and awareness

Money laundering risks from customers' tax fraud schemes

Authority / court
Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
Area of law
Money laundering and terrorist financing
Legal basis
Art. 41-1-2 Code de procédure pénale (blanchiment de fraude fiscale en bande organisée)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
18 Sep 2024

Checked against the official source on 2 Oct 2026 · Company name anonymised since 18 Sep 2026 · Direct link

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17 Sep 2024 a Swiss private bankFINMA: private bank seriously breached AML duties, CHF 12.7 million confiscated SwitzerlandCustomer due diligenceanonymised €13.5m

The Eidgenössische Finanzmarktaufsicht (FINMA, Swiss Financial Market Supervisory Authority) found that the bank, despite warnings, inadequately checked and documented beneficial ownership and the background of transactions in business relationships with complex structures possibly attributable to a now-deceased businessman accused of tax evasion, which at times held up to USD 1.7 billion. FINMA confiscated CHF 12.7 million of unlawfully earned profits, prohibited the bank from taking on new clients with increased money-laundering risks until compliance is restored, ordered a review of all client relationships and of higher-risk transactions from 2018 to 2022, and appointed an audit agent. The ruling issued in June 2023 has been final since August 2023.

What organisations can take from it

Since aggravated tax offences count as predicate offences, banks must investigate tax-risk warning signs just like other money-laundering risks.

Relevance to training and awareness

Aggravated tax offences as a predicate offence to money laundering; duty to investigate

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Finanzmarktaufsichtsrecht: Geldwäschereiprävention, angemessene Organisation und Risikomanagement (Einziehung zugunsten der Staatskasse)
Action
Disgorgement of profits
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The bank cooperated in the proceedings and took its own organisational, operational and personnel measures during the proceedings.
Liability of senior managers
FINMA opened three enforcement proceedings against individuals.
Published
17 Sep 2024

Original amount 12,700,000 CHF, converted at the ECB reference rate of 17 Sep 2024.

Sources

Checked against the official source on 2 Oct 2026 · Company name anonymised since 17 Sep 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 Hong KongCustomer due diligenceanonymised €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.

What organisations can take from it

Wallet providers must reliably turn trigger events into a fresh customer review and treat high-risk cases separately.

Relevance to training and awareness

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.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 30 Aug 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 USA, New YorkCustomer due diligenceanonymised €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.

What organisations can take from it

AML weaknesses in individual foreign units reflect on the whole group and must be managed group-wide.

Relevance to training and awareness

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.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 27 Aug 2026 · Direct link

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14 Aug 2024 a money services business based in British ColumbiaFINTRAC: CAD 229,350 penalty on money services business based in British Columbia for 5 violations of anti-money laundering obligations CanadaInternal controlsanonymised €151,737

According to FINTRAC, the company is a money services business based in Surrey, British Columbia. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 229,350 on the company on 14 August 2024. According to FINTRAC's findings, made during a compliance examination in 2022, the company committed 5 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned reporting of incoming international electronic funds transfers of CAD 10,000 or more, written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the prescribed review of the compliance programme and compliance with a ministerial directive. Specifically, FINTRAC found 21 unreported incoming international transfers; contrary to the ministerial directive on Iran, the company also failed to report 21 transactions originating from Iran. According to FINTRAC, the company has appealed the decision to the Federal Court. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 9(1), 9.6(1), 11.43; PCMLTF Regulations 28(1)(a), 71(1)(b), 71(1)(c), 71(1)(e); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
28 Nov 2024

Original amount 229,350 CAD, converted at the ECB reference rate of 14 Aug 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 14 Aug 2026 · Direct link

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12 Aug 2024 a German digital bankBaFin: EUR 1.25 million fine on a digital bank over late suspicious activity reports GermanySuspicious activity reportsanonymised €1.25m

BaFin imposed a fine of EUR 1,250,000 on a German digital bank. According to BaFin, between March 2021 and June 2023 the institution systematically filed money laundering suspicious activity reports with the FIU late. According to BaFin, the decision is final.

What organisations can take from it

Suspicious activity reports brook no delay; filing them systematically late over years can lead to a fine in the millions.

Relevance to training and awareness

Filing suspicious activity reports with the FIU on time

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
§ 56 Abs. 1 Nr. 69, Abs. 3 GwG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
1 Oct 2024

Checked against the official source on 2 Oct 2026 · Company name anonymised since 12 Aug 2026 · Direct link

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2 Aug 2024 an Abu Dhabi company service providerADGM: 32,000 USD fine for a company service provider over high-risk customer failings United Arab EmiratesCustomer due diligenceanonymised €29,534

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the company service provider 32,000 USD because, from around October 2018 to December 2022, it did not adequately verify the source of wealth of customers it had rated high risk and entered into business relationships with them without senior management approval. Relevant policies existed but were not fully implemented; without the 20% discount for early settlement the fine would have been 40,000 USD.

What organisations can take from it

Policies alone are not enough: for high-risk customers, documented senior management approval must be in place before the relationship begins.

Relevance to training and awareness

Enhanced due diligence: source of wealth and senior management approval

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Section 232 FSMR 2015; AML Rules 8.4.1(c) und 8.4.1(e)
Action
Fine
Status of proceedings
final
Sector
Other
Repeat case
no
Mitigating circumstances
No previous non-compliance, policies in place; full cooperation and remediation, including mandatory periodic AML training for all staff; 20% discount for early settlement; the failings concerned only this entity of the group.

Original amount 32,000 USD, converted at the ECB reference rate of 2 Aug 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 2 Aug 2026 · Direct link

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23 Jul 2024 a UK e-money institutionFCA: £3.5m fine for crypto exchange subsidiary over onboarding high-risk customers United KingdomInternal controlsanonymised €4.17m

The FCA fined a UK e-money institution belonging to a US crypto exchange group, £3,503,546. The FCA found that the firm had voluntarily agreed with the FCA not to onboard high-risk customers, but between October 2020 and October 2023 it repeatedly breached this and served 13,416 such customers. In the FCA's view, the cause was poorly designed, tested and monitored controls. The fine includes a 30% settlement discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Regulation 51(1)(a) Electronic Money Regulations 2011; FCA Principle 2
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 3,503,546 GBP, converted at the ECB reference rate of 23 Jul 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 23 Jul 2026 · Direct link

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18 Jul 2024 a corporate service provider in the DIFCDFSA: corporate service provider misled regulator with backdated documents – USD 210,000 United Arab EmiratesMoney laundering and terrorist financinganonymised €192,132

The company service provider, registered as a DNFBP, gave the DFSA documents that had been created and backdated after the event for an anti-money laundering risk assessment and refused access to records during a visit in March 2022. The DFSA imposed USD 210,000 and withdrew the DNFBP registration.

What organisations can take from it

Documents created or backdated after the event and given to the regulator weigh more heavily than the gap they are meant to hide.

Relevance to training and awareness

Honesty and cooperation with the regulator

Authority / court
Dubai Financial Services Authority (DFSA)
Area of law
Money laundering and terrorist financing
Action
Fine
Status of proceedings
final
Sector
Other
Mitigating circumstances
Settlement (30% discount); USD 300,000 without settlement.
Liability of senior managers
Measures against individuals are not set out here.
Published
18 Jul 2024

Original amount 210,000 USD, converted at the ECB reference rate of 18 Jul 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 18 Jul 2026 · Direct link

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17 Jul 2024 a real estate brokerage based in QuebecFINTRAC: CAD 36,360 penalty on real estate brokerage based in Quebec for 4 violations of anti-money laundering obligations CanadaCustomer due diligenceanonymised €24,323

According to FINTRAC, the company is a real estate brokerage based in Quebec. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 36,360 on the company on 17 July 2024. According to FINTRAC's findings, made during a compliance examination, the company committed 4 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, the compliance training programme and client identification. According to FINTRAC, the company is paying the penalty in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
PCMLTFA s. 6; PCMLTF Regulations 64.2, 65(4), 71(1)(b), 71(1)(d); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Published
6 May 2025

Original amount 36,360 CAD, converted at the ECB reference rate of 17 Jul 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 17 Jul 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 Hong KongCustomer due diligenceanonymised €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.

What organisations can take from it

Persons who approve payments on behalf of corporate customers also belong in identity verification.

Relevance to training and awareness

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.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 5 Jul 2026 · Direct link

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5 Jul 2024 a South African insurerPA: ZAR 13m against an insurer over flaws in its anti-money laundering programme South AfricaCustomer due diligenceanonymised €658,658

Following a FIC Act inspection in 2020, the insurer was sanctioned for inadequate customer due diligence (including on domestic prominent influential persons), missing records for client files and an inadequately developed risk management and compliance programme. It received three cautions and financial penalties of ZAR 13m (10m for customer due diligence, 3m for the RMCP), of which ZAR 6m is conditionally suspended for 36 months.

What organisations can take from it

Insurers, too, must assess money laundering risks using a documented method and keep client files complete.

Relevance to training and awareness

Risk-based customer checks and record-keeping at insurers

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 21(1), 21A–21H, 22, 23, 42
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation and remediation of the deficiencies; ZAR 6m conditionally suspended.
Published
5 Jul 2024

Original amount 13,000,000 ZAR, converted at the ECB reference rate of 5 Jul 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 5 Jul 2026 · Direct link

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27 Jun 2024 a real estate brokerage based in OntarioFINTRAC: CAD 57,750 penalty on real estate brokerage for 3 violations of anti-money laundering obligations CanadaInternal controlsanonymised €39,428

According to FINTRAC, the company is a real estate brokerage based in North York, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 57,750 on the company on 27 June 2024. According to FINTRAC's findings, made during a compliance examination in 2022, the company committed 3 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks and the prescribed review of the compliance programme. According to FINTRAC, the penalty has been paid in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTF Regulations 71(1)(b), 71(1)(c), 71(1)(e); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Published
24 Sep 2024

Original amount 57,750 CAD, converted at the ECB reference rate of 27 Jun 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 27 Jun 2026 · Direct link

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19 Jun 2024 an Italian mutual insurerIVASS fines insurer €207,500 over customer due diligence failings ItalyCustomer due diligenceanonymised €207,500

IVASS (Italian insurance supervisor) imposed a fine of 207,500 EUR on the mutual insurer under Art. 62(1) of Legislative Decree 231/2007. The insurer had not adequately identified the beneficial owners in ongoing contractual relationships and, where contracts were assigned, had gathered too little information on their purpose, on whether the premiums matched the customer's financial situation and on the source of funds.

What organisations can take from it

Insurers, too, must verify beneficial owners and the source of funds, especially when contracts are transferred to third parties.

Relevance to training and awareness

Beneficial ownership and source of funds in insurance contracts

Authority / court
IVASS (Istituto per la Vigilanza sulle Assicurazioni)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 16 Abs. 1, Art. 18 Abs. 1 lit. b und c sowie Art. 62 Abs. 1 D.Lgs. 231/2007; Art. 11, 14, 35 und 37 IVASS-Verordnung 44/2019
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
31 Jul 2024

Checked against the official source on 28 Sep 2026 · Company name anonymised since 19 Jun 2026 · Direct link

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18 Jun 2024 a Swedish cash-in-transit companyCash-in-transit company: SEK 40m for money laundering failings in cash deposit services SwedenCustomer due diligenceanonymised €3.55m

Finansinspektionen (FI, Swedish Financial Supervisory Authority) issued the cash-in-transit and payment institution a remark and an administrative fine of 40,000,000 SEK for breaches in its cash counting business (uppräkningsverksamhet). The general risk assessment did not adequately address geographical risks and cash-intensive customers, customers were not risk-assessed individually, and there were shortcomings in both basic and enhanced due diligence – in some cases no information at all was obtained on the purpose and nature of the business relationship; cash deposits of 11.7 billion SEK from foreign banks were processed without sufficient checks on the source of funds.

What organisations can take from it

Cash-intensive services require a risk assessment for each customer and robust source-of-funds checks, especially for deposits from abroad.

Relevance to training and awareness

Customer due diligence and source-of-funds checks for cash-intensive customers

Authority / court
Finansinspektionen (FI)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Lag (2017:630) om åtgärder mot penningtvätt och finansiering av terrorism, u. a. 2 kap. 1–3 §§, 3 kap. 12 och 16 §§; 8 kap. 8 och 14 §§ lagen (2010:751) om betaltjänster
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Published
19 Jun 2024

Original amount 40,000,000 SEK, converted at the ECB reference rate of 18 Jun 2024.

Checked against the official source on 28 Sep 2026 · Company name anonymised since 18 Jun 2026 · Direct link

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18 Jun 2024 a Swiss private bankFINMA: Swiss private bank breached anti-money laundering rules for two PEPs SwitzerlandCustomer due diligenceanonymised Order

The Swiss Financial Market Supervisory Authority (FINMA) found that, for two politically exposed persons, the bank insufficiently clarified the origin and purpose of assets – transactions of more than 300 million USD from a Lebanese state institution between 2002 and 2015 – and only reported them to the reporting office in September 2020. It ordered a review of all PEP relationships, a ban on new PEP relationships until the review is completed and the appointment of an audit agent; the decision was not final at the time of publication (date of the announcement used as decision date).

What organisations can take from it

In PEP relationships, document the origin and purpose of large payments; a report made years later is no report.

Relevance to training and awareness

Dealing with politically exposed persons (PEPs)

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Schweizer Geldwäschereirecht (laut FINMA)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Published
18 Jun 2024
Sources

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 18 Jun 2026 · Direct link

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7 Jun 2024 an Australian casino operatorAustralian casino operator: 67 million AUD for anti-money laundering breaches AustraliaMoney laundering and terrorist financinganonymised €41m

On application by AUSTRAC (Australian Transaction Reports and Analysis Centre, Australia's anti-money laundering regulator and financial intelligence unit), the Federal Court of Australia on 7 June 2024 imposed a penalty of 67 million AUD on the casino operator for contraventions of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006; the casino operator must also pay AUSTRAC's costs of 3 million AUD. AUSTRAC had brought the proceedings in December 2022 following its own supervisory work in the casino sector, having identified serious and systemic non-compliance with anti-money laundering obligations.

What organisations can take from it

Supervisors examine entire sectors proactively; businesses operating in them should test the effectiveness of their anti-money laundering programme themselves before the regulator does.

Relevance to training and awareness

Anti-money laundering in casino and gambling operations

Authority / court
Federal Court of Australia (auf Antrag des Australian Transaction Reports and Analysis Centre, AUSTRAC)
Area of law
Money laundering and terrorist financing
Legal basis
Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)
Action
Fine
Status of proceedings
unknown
Sector
Other

Original amount 67,000,000 AUD, converted at the ECB reference rate of 7 Jun 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 7 Jun 2026 · Direct link

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7 Jun 2024 a South African branch of a foreign bankPA: ZAR 30.5m against a foreign bank's branch over customer due diligence failures South AfricaCustomer due diligenceanonymised €1.49m

Following a FIC Act inspection in 2021 (samples from 2016–2020), the supervisor sanctioned the South African branch for failing to carry out (enhanced) customer due diligence, late suspicious transaction reports, monitoring alerts not handled on time and an inadequate risk management and compliance programme. It imposed four cautions, a reprimand and financial penalties totalling ZAR 30.5m (20m for due diligence, 0.5m for alert handling, 10m for the RMCP), of which ZAR 15.25m is conditionally suspended for 36 months. According to the supervisor, the sanctions do not stem from any involvement of the branch in money laundering or terrorist financing transactions.

What organisations can take from it

Foreign branches also need their own anti-money laundering programme, approved by the governing body, that actually drives customer due diligence and alert handling.

Relevance to training and awareness

Customer due diligence and timely handling of monitoring alerts

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 21(1), 21A, 29 i. V. m. Regulation 24(3), s. 42; FIC Directive 5 of 2019
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation with the supervisor and remedial action; half of the penalty was conditionally suspended.
Liability of senior managers
The programme had not been approved by the Board of Directors and was not tailored to the branch.
Published
7 Jun 2024

Original amount 30,500,000 ZAR, converted at the ECB reference rate of 7 Jun 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 7 Jun 2026 · Direct link

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5 Jun 2024 a German car dealerCar dealer: 12,866 EUR fine for breach of AML due diligence obligations GermanyCustomer due diligenceanonymised €12,866

A fine of 12,866 EUR, final since 5 June 2024, was imposed on the motor vehicle dealer by the Arnsberg regional government (Bezirksregierung Arnsberg), as anti-money laundering supervisor for the non-financial sector, for breach of the due diligence obligations of the German Money Laundering Act (Geldwäschegesetz, GwG), and the company was publicly named.

What organisations can take from it

Car dealerships must identify and document buyers for cash payments of 10,000 EUR or more – sales staff must know the threshold.

Relevance to training and awareness

Customer identification when selling vehicles for cash

Authority / court
Bezirksregierung Arnsberg (Geldwäscheaufsicht Nichtfinanzsektor)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Geldwäschegesetz (Sorgfaltspflichten); Bekanntmachung nach § 57 GwG
Action
Fine
Status of proceedings
final
Sector
Automotive

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 5 Jun 2026 · Direct link

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31 May 2024 a money services business based in British ColumbiaFINTRAC: CAD 33,000 penalty on money services business for one violation of anti-money laundering obligations CanadaInternal controlsanonymised €22,291

According to FINTRAC, the company is a money services business based in Richmond, British Columbia. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 33,000 on the company on 31 May 2024. According to FINTRAC's findings, the company committed one violation of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violation concerned money services business registration requirements. According to FINTRAC, the penalty has been paid in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 11.19; PCMLTF Registration Regulations s. 4(e), 5, 6.1; Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
19 Sep 2024

Original amount 33,000 CAD, converted at the ECB reference rate of 31 May 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 31 May 2026 · Direct link

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8 May 2024 a Luxembourg bankLuxembourg bank: EUR 3m for AML failings concerning a group of related clients LuxembourgSuspicious activity reportsanonymised €3m

The CSSF fined the credit institution EUR 3,000,000. An inspection from May to November 2021 covering a group of related high-risk clients found deficient enhanced due diligence on source of funds and wealth, inadequate transaction monitoring and failures to report to the Cellule de Renseignement Financier (Luxembourg FIU), including when business relationships were closed despite suspicious indicators. In addition, individual employees had told a client, unprompted, about a block ordered by the FIU.

What organisations can take from it

Before ending a suspicious client relationship, a firm must inform the FIU and must never disclose an ordered block to the client.

Relevance to training and awareness

Reporting suspicions before ending a client relationship and the prohibition on tipping off

Authority / court
Commission de Surveillance du Secteur Financier (CSSF)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Art. 2-1(1), 8-4(1)-(3) und 8-5 Loi modifiée du 12 novembre 2004 (LBC/FT), verletzt u. a. Art. 2-2, 3, 3-2 und 5; Règlement grand-ducal du 1er février 2010; Règlement CSSF 12-02
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Full cooperation with the CSSF, a general action plan and remedial measures during and after the inspection.
Published
8 Jul 2024

Checked against the official source on 2 Oct 2026 · Company name anonymised since 8 May 2026 · Direct link

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7 May 2024 a foreign crypto exchangeFINTRAC: CAD 6,002,000 penalty on foreign crypto exchange for 2 violations of anti-money laundering obligations CanadaInternal controlsanonymised €4.07m

According to FINTRAC, the company is an entity determined to be a foreign money services business operating in Canada. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 6,002,000 on the company on 7 May 2024. According to FINTRAC's findings, the company committed 2 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned money services business registration requirements and large virtual currency transaction reporting. According to FINTRAC, the company had not completed registration despite several opportunities and deadlines; the regulator identified unreported virtual currency receipts of CAD 10,000 or more using blockchain analytics. According to FINTRAC, the company has appealed the decision to the Federal Court. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 11.1; PCMLTF Regulations 30(1)(f); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
9 May 2024

Original amount 6,002,000 CAD, converted at the ECB reference rate of 7 May 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 7 May 2026 · Direct link

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2 May 2024 an Icelandic commercial bankIceland: commercial bank pays 585 million ISK over anti-money laundering failings IcelandCustomer due diligenceanonymised €3.9m

The financial supervisory authority of Seðlabanki Íslands (Central Bank of Iceland) concluded proceedings against an Icelandic commercial bank with a settlement in which the bank admitted breaches of Act No. 140/2018 on anti-money laundering, pays 585,000,000 ISK and commits to remedial measures. An on-site inspection in 2022 had found deficiencies in risk assessment, risk classification of business relationships, anonymous transactions, due diligence on foreign financial institutions, enhanced due diligence, business with a high-risk country and ongoing monitoring, including the traceability of cash transactions; some breaches repeated findings from a 2020 inspection.

What organisations can take from it

Findings from a supervisory inspection must be remedied for good, because repeated deficiencies count towards a higher sanction.

Relevance to training and awareness

Money laundering prevention: risk assessment, enhanced due diligence and cash transactions

Authority / court
Seðlabanki Íslands – Fjármálaeftirlit (Finanzaufsicht)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 5 Abs. 1, 7 Abs. 1, 10 Abs. 1, 2, 4 Bst. a und 5, 13 Abs. 1 Bst. c, 3 und 4, 15, 21 Abs. 1 Bst. a und 2 sowie 34 Abs. 1 Gesetz Nr. 140/2018 über Maßnahmen gegen Geldwäsche und Terrorismusfinanzierung (damalige Fassung) i.V.m. Verordnung Nr. 745/2019; Geldbuße nach Art. 46 Abs. 1, Vergleich nach Art. 47 Gesetz Nr. 140/2018
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
Willingness to cooperate: the bank took the inspection findings seriously and took the initiative on remediation.
Published
28 Jun 2024

Original amount 585,000,000 ISK, converted at the ECB reference rate of 2 May 2024.

Checked against the official source on 28 Sep 2026 · Company name anonymised since 2 May 2026 · Direct link

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24 Apr 2024 a German neobankBaFin: 9.2 million EUR against neobank over systematically late suspicious activity reports GermanySuspicious activity reportsanonymised €9.2m

By final decision of 24 April 2024, Germany's Federal Financial Supervisory Authority (BaFin) imposed a fine of 9.2 million EUR on the neobank because it had systematically filed money laundering suspicious activity reports late in 2022.

What organisations can take from it

Send suspicious activity reports to the FIU without delay – systematically late reporting risks fines running into millions.

Relevance to training and awareness

Suspicious activity reports without delay

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
§ 56 Abs. 1 Nr. 69, Abs. 3 GwG (verspätete Verdachtsmeldungen, § 43 Abs. 1 GwG); Bekanntmachung nach § 57 GwG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
21 May 2024

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 24 Apr 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 Hong KongInternal controlsanonymised €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.

What organisations can take from it

A new monitoring system is no substitute for oversight: whether its alerts are actually reviewed must be checked continuously.

Relevance to training and awareness

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.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 19 Apr 2026 · Direct link

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19 Apr 2024 a Canadian securities dealer and portfolio managerFINTRAC: CAD 49,500 penalty on securities dealer for 2 violations of anti-money laundering obligations CanadaInternal controlsanonymised €33,752

According to FINTRAC, the company is a securities dealer or wealth management firm. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 49,500 on the company on 19 April 2024. According to FINTRAC's findings, made during a compliance examination in 2022, the company committed 2 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures and assessing and documenting money laundering and terrorist financing risks. According to FINTRAC, the penalty has been paid in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTF Regulations 71(1)(b), 71(1)(c); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
31 Jul 2024

Original amount 49,500 CAD, converted at the ECB reference rate of 19 Apr 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 19 Apr 2026 · Direct link

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9 Apr 2024 a major Canadian bankFINTRAC: CAD 9,185,000 penalty on major Canadian bank for 5 violations of anti-money laundering obligations CanadaSuspicious activity reportsanonymised €6.23m

According to FINTRAC, the company is a bank based in Toronto, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 9,185,000 on the company on 9 April 2024. According to FINTRAC's findings, made during a compliance examination in 2023, the company committed 5 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, assessing and documenting money laundering and terrorist financing risks, enhanced measures for high-risk situations and ongoing monitoring of business relationships. Specifically, FINTRAC found 20 missing suspicious transaction reports in 178 case files reviewed; the bank also exercised insufficient oversight of its client risk rating during a system transition, so that 85 clients were not subject to the required special measures and in 96 cases no reassessment and monitoring was documented. FINTRAC stresses that the penalty was imposed for administrative violations and not for money laundering or terrorist financing offences. According to FINTRAC, the penalty has been paid in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 6, 7, 9.6(3); PCMLTF Regulations 123.1, 146(1), 156(1)(c), 156(2), 157; PCMLTF Suspicious Transaction Reporting Regulations s. 9(1); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
2 May 2024

Original amount 9,185,000 CAD, converted at the ECB reference rate of 9 Apr 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 9 Apr 2026 · Direct link

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4 Apr 2024 two online licensees of a British betting groupBetting group: £582,120 – including no sanctions screening before first deposit United KingdomCustomer due diligenceanonymised €678,556

The two online licensees of a betting group will pay a total of £582,120, directed to socially responsible causes, under a settlement (the gaming company £343,035, the sports betting company £239,085). An assessment in March 2022 found ineffective triggers for enhanced due diligence and know-your-customer checks, no screening of new customers against financial sanctions lists before their first deposit, over-reliance on customers' annual self-verification and customer interactions that were not tailored to the individual and of limited effect. For the customers reviewed, the Commission found no evidence of criminal funds or of funds from sanctioned persons; each company also pays £15,684.50 towards the Commission's investigation costs.

What organisations can take from it

New customers must be screened against financial sanctions lists before their first deposit.

Relevance to training and awareness

Sanctions screening of new customers and independent verification of KYC information

Authority / court
Gambling Commission
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
s. 116 Gambling Act 2005; LC 12.1.1 Abs. 2, LC 12.1.2 (nur Hillside (UK Gaming) ENC) und SRCP 3.4.1 Abs. 1b und 1c der Licence Conditions and Codes of Practice (LCCP); Reg. 28(11)(a) und 33 Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
Action
Fine
Status of proceedings
final
Sector
Other
Mitigating circumstances
The extent of the remedial steps taken and timely cooperation with the investigation.
Published
4 Apr 2024

Original amount 582,120 GBP, converted at the ECB reference rate of 4 Apr 2024.

Checked against the official source on 3 Oct 2026 · Company name anonymised since 4 Apr 2026 · Direct link

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28 Mar 2024 a Swiss private bankPrivate bank fined CHF 750,000 for organisational failings over money laundering SwitzerlandInternal controlsanonymised €767,971

In the Lava Jato case complex, the Bundesanwaltschaft (BA, Office of the Attorney General of Switzerland) found that between 2011 and 2014 a Swiss private bank did not adequately establish beneficial owners and the background of transactions at its Lugano office, enabling two employees to commit money laundering exceeding USD 20 million. By summary penalty order of 28 March 2024 the bank was fined CHF 750,000; the BA dropped the charge of bribery of foreign public officials. The bank waived its right to object, so the penalty order becomes final.

What organisations can take from it

For accounts with conspicuous structures, beneficial ownership must be checked independently of the relationship manager.

Relevance to training and awareness

Establishing beneficial owners and front-man structures

Authority / court
Bundesanwaltschaft (BA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 102 Abs. 2 StGB i.V.m. Art. 305bis Ziff. 2 StGB
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The bank's cooperation with the Office of the Attorney General was taken into account.
Published
4 Apr 2024

Original amount 750,000 CHF, converted at the ECB reference rate of 28 Mar 2024.

Checked against the official source on 2 Oct 2026 · Company name anonymised since 28 Mar 2026 · Direct link

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25 Mar 2024 a Swiss bankFINMA confiscates 3.9 million CHF in profits from Swiss bank SwitzerlandSuspicious activity reportsanonymised €4.01m

The Swiss Financial Market Supervisory Authority (FINMA) found serious infringements of anti-money laundering rules in PEP relationships: insufficient clarification of the origin of assets, failure to report to the reporting office despite unexplained transaction purposes and a serious breach of the duty to provide information, because a critical internal audit report was not handed over. It confiscated 3.9 million CHF in profits, imposed a capital surcharge of 19 million CHF and a two-year ban on new PEP and high-risk relationships (date of the announcement used as decision date).

What organisations can take from it

Withholding critical audit reports from the supervisory authority considerably aggravates a money laundering case.

Relevance to training and awareness

PEP clarifications and openness towards the supervisory authority

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Schweizer Geldwäschereirecht; Gewinneinziehung und Auskunftspflicht nach Finanzmarktaufsichtsrecht (laut FINMA)
Action
Disgorgement of profits
Status of proceedings
unknown
Sector
Financial services and insurance
Published
25 Mar 2024

Original amount 3,900,000 CHF, converted at the ECB reference rate of 25 Mar 2024.

Sources

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 25 Mar 2026 · Direct link

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13 Mar 2024 a real estate brokerage based in OntarioFINTRAC: CAD 107,827.50 penalty on real estate brokerage based in Ontario for 6 violations of anti-money laundering obligations CanadaCustomer due diligenceanonymised €73,074

According to FINTRAC, the company is a real estate brokerage based in Toronto, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 107,827.50 on the company on 13 March 2024. According to FINTRAC's findings, made during a compliance examination in 2022, the company committed 6 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the compliance training programme, the prescribed review of the compliance programme, record keeping and client identification. Specifically, FINTRAC criticised among other things a risk assessment based on a generic checklist, incomplete records and 14 cases in which identification details were missing for persons who provided funds for real estate transactions. According to FINTRAC, the penalty has been paid in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
PCMLTF Regulations 39(1), 64.2, 71(1)(b), 71(1)(c), 71(1)(d), 71(1)(e); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Published
29 Oct 2024

Original amount 107,827.5 CAD, converted at the ECB reference rate of 13 Mar 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 13 Mar 2026 · Direct link

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11 Mar 2024 a German major bankBaFin fines a major bank €1.45m for supervisory failings in AML compliance GermanyCustomer due diligenceanonymised €1.45m

BaFin (German Federal Financial Supervisory Authority) imposed two fines of 375,000 EUR and 1,075,000 EUR, 1,450,000 EUR in total, on a German major bank, also as universal successor of a direct bank merged into it. Owing to inadequate supervision, employees had not updated customer data on time or sufficiently, internal safeguards were inadequate, and enhanced due diligence was insufficiently applied in three cases. The decision of 11 March 2024 has been final since 28 March 2024.

What organisations can take from it

Work instructions on updating customer data are only sufficient if management effectively monitors compliance with them.

Relevance to training and awareness

Updating customer data regularly and applying enhanced due diligence

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 130 Abs. 1 OWiG i. V. m. § 56 Abs. 1 S. 1 Nr. 3, Nr. 20, Nr. 32, Nr. 34 und Nr. 35 GwG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
The fine punished a breach of the duty of supervision within the company (§ 130 OWiG, German Administrative Offences Act): inadequate oversight enabled the employees' breaches.
Published
22 Apr 2024

Checked against the official source on 2 Oct 2026 · Company name anonymised since 11 Mar 2026 · Direct link

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28 Feb 2024 a South African fund managerSouth African fund manager: ZAR 16m for failings in anti-money laundering controls South AfricaInternal controlsanonymised €769,760

An inspection in October and November 2022 found that the risk management and compliance programme (RMCP) of the fund manager, a subsidiary of a banking group, was deficient, that some clients and beneficial owners had not been identified and verified, and that clients had not been screened against the UN targeted financial sanctions lists. A penalty of 16 million ZAR was imposed, of which 6 million ZAR was suspended for three years; 10 million ZAR was payable by 28 February 2024, together with a directive to remedy the remaining deficiencies.

What organisations can take from it

An anti-money laundering programme must not merely exist but must specifically cover client identification, beneficial owners and screening against sanctions lists.

Relevance to training and awareness

Customer due diligence, beneficial owners and sanctions-list screening

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Sections 42(1), 42(2), 21(1), 21B und 28A i. V. m. 26A–26C Financial Intelligence Centre Act 38 of 2001 (FIC Act)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Remedial action already taken; 6 million ZAR suspended for three years, provided the directive is fully implemented and the relevant obligations are complied with.
Published
28 Feb 2024

Original amount 16,000,000 ZAR, converted at the ECB reference rate of 28 Feb 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 28 Feb 2026 · Direct link

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11 Feb 2024 a money services business based in British ColumbiaFINTRAC: CAD 315,282 penalty on money services business for 6 violations of anti-money laundering obligations CanadaSuspicious activity reportsanonymised €217,646

According to FINTRAC, the company is a money services business based in Richmond, British Columbia. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 315,282 on the company on 11 February 2024. According to FINTRAC's findings, made during a compliance examination in 2022, the company committed 6 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, large cash transaction reporting, international electronic funds transfer reporting, written compliance policies and procedures and assessing and documenting money laundering and terrorist financing risks. Specifically, for 2020 and 2021 FINTRAC found two missing suspicious transaction reports, three unfiled reports of cash receipts of CAD 10,000 or more, and 25 outgoing and four incoming international transfers that were not reported; the client risk assessment was not applied in practice. According to FINTRAC, the penalty has been paid in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9(1), 9.6(1); PCMLTF Regulations 28(1)(a), 28(1)(b), 28(1)(c), 71(1)(b), 71(1)(c); PCMLTF Suspicious Transaction Reporting Regulations s. 9(1); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
12 Sep 2024

Original amount 315,282 CAD, converted at the ECB reference rate of 9 Feb 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 11 Feb 2026 · Direct link

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6 Feb 2024 a German digital bankBaFin fines a digital bank €6.5m for systematically late suspicious activity reports GermanySuspicious activity reportsanonymised €6.5m

BaFin (Bundesanstalt für Finanzdienstleistungsaufsicht, German Federal Financial Supervisory Authority) imposed a fine of 6,500,000 EUR on a German digital bank because the institution had systematically filed money laundering suspicious activity reports with the Financial Intelligence Unit (FIU) too late. The decision of 6 February 2024 is final.

What organisations can take from it

Anyone who lets suspicious activity reports slip risks fines in the millions; reporting processes need sufficient capacity and effective deadline control.

Relevance to training and awareness

Reporting suspicious cases to the FIU without delay

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
§ 56 Abs. 1 Nr. 69, Abs. 3 GwG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
7 Mar 2024

Checked against the official source on 2 Oct 2026 · Company name anonymised since 6 Feb 2026 · Direct link

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10 Jan 2024 a Luxembourg life insurerLuxembourg life insurer: 1.68 million EUR over missing overall money laundering risk assessment LuxembourgInternal controlsanonymised €1.68m

During an inspection in 2021/2022, the Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) found that the life insurer had not prepared an overall assessment of its money laundering risks, that guidance for employees on due diligence obligations (beneficial owners, high-risk countries, PEPs) was inadequate and that it was not checked whether the intermediaries used fulfilled their due diligence obligations. It imposed 1,682,000 EUR.

What organisations can take from it

Without a documented overall risk assessment, a risk-based approach cannot be demonstrated – intermediaries must also be monitored.

Relevance to training and awareness

Due diligence obligations regarding beneficial owners and PEPs

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Loi modifiée du 12 novembre 2004 (LBC/FT), Art. 2-1, 2-2, 8-4, 8-5; Règlement CAA 20/03
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
20 Mar 2024

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 10 Jan 2026 · Direct link

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8 Jan 2024 a real estate brokerage based in British ColumbiaFINTRAC: CAD 83,655 penalty on real estate brokerage for 5 violations of anti-money laundering obligations CanadaCustomer due diligenceanonymised €57,098

According to FINTRAC, the company is a real estate brokerage based in West Vancouver, British Columbia. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 83,655 on the company on 8 January 2024. According to FINTRAC's findings, made during a compliance examination in 2021, the company committed 5 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the prescribed review of the compliance programme, record keeping and client identification. Specifically, FINTRAC found among other things that no third-party determination had been documented, that three of 25 client records reviewed were incomplete and that identification details were missing for two persons who provided funds. According to FINTRAC, the penalty has been paid in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
PCMLTF Regulations 39(1)(b), 64.2, 71(1)(b), 71(1)(c), 71(1)(e); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Published
16 Jul 2024

Original amount 83,655 CAD, converted at the ECB reference rate of 8 Jan 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 8 Jan 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 Hong KongInternal controlsanonymised €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.

What organisations can take from it

Payment and e-money providers must treat transaction monitoring, governance and internal controls alike as conditions of their licence.

Relevance to training and awareness

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.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 18 Dec 2025 · Direct link

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8 Dec 2023 a South African bankPA: ZAR 10.73m against a bank over weak controls and agent-sourced clients South AfricaInternal controlsanonymised €526,866

Following an inspection in 2020, the supervisor found deficiencies in the risk management and compliance programme (including identification of beneficial owners, clients onboarded by agents and shared clients), in customer due diligence and record-keeping, in the calibration of transaction monitoring and in governance. It imposed reprimands, cautions and financial penalties totalling ZAR 10.73m (1.5m, 4m, 5m and 0.23m), of which ZAR 5m is conditionally suspended for 24 months.

What organisations can take from it

A bank that acquires clients through agents or outsources due diligence to third parties remains responsible for oversight and monitoring itself.

Relevance to training and awareness

Oversight of agents and outsourcing of due diligence duties

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 21–21H, 22–24, 42(1), 42(2), 42(2A), 42A(2), 42A(3), 45C(3); FIC Directive 5/2019
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation and remedial action; ZAR 5m conditionally suspended.
Liability of senior managers
Governance duties were also criticised, including oversight of agent relationships and remediation of known deficiencies.
Published
8 Dec 2023

Original amount 10,730,000 ZAR, converted at the ECB reference rate of 8 Dec 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 8 Dec 2025 · Direct link

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6 Dec 2023 a Latvian bankLatvia: bank pays 2.02 million EUR over anti-money-laundering failings LatviaInternal controlsanonymised €2.02m

Latvijas Banka (Bank of Latvia) concluded an administrative agreement with the bank under which the bank acknowledged breaches of the rules on preventing money laundering and terrorist and proliferation financing, accepted a fine of 2,016,342 EUR and undertook to improve its internal control system. The basis was a 2.2 million EUR fine imposed by the FKTK in 2018 that was still being challenged in court, together with inspections in 2021 and 2023 that found shortcomings in, among other things, risk management, internal audit, customer due diligence, transaction monitoring, safe-deposit risks and suspicious transaction reporting.

What organisations can take from it

Supervisory findings on anti-money-laundering controls should be acknowledged and remedied promptly before they accumulate into larger sanctions over years.

Relevance to training and awareness

Customer due diligence and suspicious activity reporting in banks

Authority / court
Latvijas Banka (Lettische Zentralbank, Finanzaufsicht)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Noziedzīgi iegūtu līdzekļu legalizācijas un terorisma un proliferācijas finansēšanas novēršanas likums; Verwaltungsvertrag (administratīvais līgums)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The bank acknowledged the breaches, had taken remedial measures and drawn up a plan to improve its control system; this was the precondition for the agreement and the reduced fine. It also undertook to ask the court to discontinue its proceedings against the 2018 FKTK decision.
Published
6 Dec 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 6 Dec 2025 · Direct link

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5 Dec 2023 a Spanish bankEUR 17.6m fine on a Spanish bank for failing to file a suspicious transaction report SpainSuspicious activity reportsanonymised €17.6m

The Consejo de Ministros (Spanish Council of Ministers) imposed a fine of 17,601,000 EUR and a public reprimand on a Spanish bank that has since been absorbed by another institution. The bank had not filed a suspicious transaction report although indications of money laundering or terrorist financing had been raised internally, and it had also breached the duty to examine unusual transactions with special care. The decision is not final.

What organisations can take from it

Internal suspicion reports from staff must be examined promptly and passed on to the financial intelligence unit; sitting on such reports is punished as a very serious infringement.

Relevance to training and awareness

Handling internal money laundering suspicion reports

Authority / court
Consejo de Ministros (auf Vorschlag der Comisión de Prevención del Blanqueo de Capitales e Infracciones Monetarias)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Art. 51.1.a) i. V. m. Art. 18 sowie Art. 52.1.g) i. V. m. Art. 17 Ley 10/2010 de prevención del blanqueo de capitales y de la financiación del terrorismo; Art. 56
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Employees
10,000 or more
Published
20 Dec 2025
Sources

Checked against the official source on 28 Sep 2026 · Company name anonymised since 5 Dec 2025 · Direct link

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30 Nov 2023 a bank in South AfricaBank in South Africa: ZAR 19.75m for failings in customer due diligence and reporting South AfricaCustomer due diligenceanonymised €960,122

Following a 2020 inspection, the supervisor identified failings at the bank in customer due diligence, cash threshold reporting, late and incomplete suspicious transaction reports, the handling of automated transaction monitoring alerts, staff training and the governance of anti-money laundering compliance. By a notice of sanction dated 30 November 2023 it imposed cautions, reprimands and penalties totalling 19.75 million ZAR, of which 9.25 million ZAR is conditionally suspended for 36 months.

What organisations can take from it

Automated transaction monitoring only helps if alerts are dealt with on time and suspicious transaction reports are filed in full.

Relevance to training and awareness

Filing suspicious transaction reports on time and in full

Missing or inadequate training played a role in the decision.

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Sections 21, 21A–21H, 28, 29 (i. V. m. Regulation 24(3)), 42, 42A und 43 Financial Intelligence Centre Act 38 of 2001; FIC Directive 5 of 2019; Sanktion nach Section 45C(3) FIC Act
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation with the supervisor and remedial action; 9.25 million ZAR suspended for 36 months. The supervisor stresses that no involvement in money laundering or terrorist financing was found.
Published
8 Dec 2023

Original amount 19,750,000 ZAR, converted at the ECB reference rate of 30 Nov 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 30 Nov 2025 · Direct link

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24 Nov 2023 a Lithuanian e-money institutionE-money institution: 840,000 EUR for anti-money laundering delegated to partners without oversight LithuaniaCustomer due diligenceanonymised €840,000

The e-money institution had delegated anti-money laundering tasks to its distribution partners without monitoring them; customer profiles were often not completed, risks (including from crypto-assets) were not assessed, monitoring was insufficient and the second and third lines of defence for ICT risks were missing. Fine of 840,000 EUR, obligation to remedy the deficiencies and restriction on business expansion.

What organisations can take from it

AML duties can be delegated to distribution partners, responsibility cannot – without oversight of the partners, the institution is liable.

Authority / court
Lietuvos bankas (Litauische Zentralbank, Finanzaufsicht)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Pinigų plovimo ir teroristų finansavimo prevencijos įstatymas; IKT-Risikomanagement-Anforderungen
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The institution submitted a remediation plan and had initiated first steps.
Published
24 Nov 2023

Checked against the official source on 28 Sep 2026 · Version 5 · Company name anonymised since 24 Nov 2025 · Direct link

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22 Nov 2023 a British online gambling operatorOnline casino: GBP 5.91m over circumventable AML thresholds and weak customer interaction United KingdomCustomer due diligenceanonymised €6.79m

The Gambling Commission imposed a warning, a licence condition requiring an external audit and a penalty of GBP 5,906,250 on the operator of twelve websites. A further GBP 165,042 was ordered as divestment; that sum is not included in the stated penalty. Between November 2021 and July 2022, the authority found that some customers were able to get round AML thresholds, due diligence relied too heavily on internet research or customers' verbal assurances, and customers at risk were contacted too late or inadequately.

What organisations can take from it

Verbal assurances and internet research are no substitute for robust evidence of the source of funds.

Relevance to training and awareness

Robust due diligence rather than verbal assurances; effective customer interaction

Authority / court
Gambling Commission
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
LC 12.1.1 Abs. 2 und LC 12.1.2 Abs. 1, SRCP 3.4.1 Abs. 1–2 und OCP 2.1.1 der Licence Conditions and Codes of Practice (LCCP); s. 117 Gambling Act 2005
Action
Fine
Status of proceedings
unknown
Sector
Other
Mitigating circumstances
The company cooperated and stated it had taken corrective steps; the Commission found no evidence of criminal funds deposited by the customers reviewed.
Published
10 Jan 2024

Original amount 5,906,250 GBP, converted at the ECB reference rate of 22 Nov 2023.

Checked against the official source on 3 Oct 2026 · Company name anonymised since 22 Nov 2025 · Direct link

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21 Nov 2023 a Hungarian major bankHungarian major bank: 49.4 million HUF over late suspicious transaction reports HungarySuspicious activity reportsanonymised €130,215

The bank did not report several suspicious cases to the financial intelligence unit without delay, its monitoring produced delayed hits owing to incorrectly set filter parameters, and its risk assessment, customer due diligence and documentation of anti-money laundering training showed deficiencies. The Magyar Nemzeti Bank (Central Bank of Hungary, MNB) imposed a total of 49.375 million HUF and set deadlines for remediation by August 2024.

What organisations can take from it

Validate monitoring parameters regularly – and training is expressly among the obligations that are inspected.

Relevance to training and awareness

Recognising and reporting suspected money laundering in good time

Missing or inadequate training played a role in the decision.

Authority / court
Magyar Nemzeti Bank (MNB)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Ungarisches Geldwäschegesetz (Pmt.)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Culpability
negligent
Mitigating circumstances
The bank had already initiated remedial measures for several of the infringements.
Published
21 Nov 2023

Original amount 49,375,000 HUF, converted at the ECB reference rate of 21 Nov 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 21 Nov 2025 · Direct link

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7 Nov 2023 a money services business based in OntarioFINTRAC: CAD 252,285 penalty on money services business for 7 violations of anti-money laundering obligations CanadaCustomer due diligenceanonymised €171,868

According to FINTRAC, the company is a money services business based in Thornhill, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 252,285 on the company on 7 November 2023. According to FINTRAC's findings, made during a compliance examination in 2021, the company committed 7 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, compliance with a ministerial directive, record keeping, client identification and money services business registration requirements. Specifically, FINTRAC found that the company did not comply with the ministerial directive on transactions involving Iran and did not treat such transactions as high risk, that prescribed information was missing from all 32 foreign exchange tickets and all 142 transfer records reviewed, and that there was no written agreement with its agent in Iran for identity verification. According to FINTRAC, the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
PCMLTFA s. 11.43; PCMLTF Regulations 30(e), 30(f), 64.1(3), 71(1)(b), 71(1)(c); PCMLTF Registration Regulations s. 4(b), 5; Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
11 Jul 2024

Original amount 252,285 CAD, converted at the ECB reference rate of 7 Nov 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 7 Nov 2025 · Direct link

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3 Nov 2023 a major Canadian bankFINTRAC: CAD 7,475,000 penalty on major Canadian bank for 3 violations of anti-money laundering obligations CanadaSuspicious activity reportsanonymised €5.1m

According to FINTRAC, the company is a bank. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 7,475,000 on the company on 3 November 2023. According to FINTRAC's findings, made during a compliance examination in 2022, the company committed 3 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting and written compliance policies and procedures. Specifically, FINTRAC found 16 missing suspicious transaction reports in 130 case files reviewed, including cases in which the bank had been served with production orders concerning clients; until May 2021 the bank also combined transactions from several branches in a single report (29 of 34 reports in a sample), and its policies gave inconsistent guidance on suspicious transaction reporting. FINTRAC stresses that the penalty was imposed for administrative violations and not for money laundering or terrorist financing offences. According to FINTRAC, the penalty has been paid in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9.6(1); PCMLTF Regulations 71(1)(b); PCMLTF Suspicious Transaction Reporting Regulations s. 9(1); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
5 Dec 2023

Original amount 7,475,000 CAD, converted at the ECB reference rate of 3 Nov 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 3 Nov 2025 · Direct link

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23 Oct 2023 a major Canadian bankFINTRAC: CAD 1,329,150 penalty on major Canadian bank for 2 violations of anti-money laundering obligations CanadaSuspicious activity reportsanonymised €914,008

According to FINTRAC, the company is a bank based in Toronto, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 1,329,150 on the company on 23 October 2023. According to FINTRAC's findings, the company committed 2 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting and international electronic funds transfer reporting. Specifically, FINTRAC found one missed suspicious transaction report concerning a client who had been arrested and charged, and 1,003 unreported incoming international transfers in a sample of 20,000. FINTRAC stresses that the penalty was imposed for administrative violations and not for money laundering or terrorist financing offences. According to FINTRAC, the penalty has been paid in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7; PCMLTF Regulations 12(1)(c); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
7 Dec 2023

Original amount 1,329,150 CAD, converted at the ECB reference rate of 23 Oct 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 23 Oct 2025 · 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 USACustomer due diligenceanonymised €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.

What organisations can take from it

In fintech partnerships the bank remains responsible for identity verification and fraud prevention, even when a programme manager distributes the accounts.

Relevance to training and awareness

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.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 16 Oct 2025 · Direct link

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16 Oct 2023 a Luxembourg life insurerLuxembourg life insurer: 790,000 EUR over deficiencies in anti-money laundering LuxembourgInternal controlsanonymised €790,000

An inspection in 2021 revealed that the life insurer had not carried out an overall assessment of its money laundering risks and that the guidance for employees on due diligence obligations (beneficial owners, high-risk countries, PEPs) was inadequate. The Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) imposed 790,000 EUR.

What organisations can take from it

The overall money laundering risk assessment is the basis of all due diligence obligations and must be in place before new business relationships are entered into.

Relevance to training and awareness

Customer due diligence in insurance distribution

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Loi modifiée du 12 novembre 2004 (LBC/FT), Art. 2-1, 2-2, 8-4, 8-5; Règlement CAA 20/03
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
3 Jul 2024

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 16 Oct 2025 · Direct link

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10 Oct 2023 a Korean life insurerKorean life insurer filed suspicious transaction and cash reports late: KoFIU fine South KoreaSuspicious activity reportsanonymised €53,166

The Korea Financial Intelligence Unit (KoFIU, Korea's financial intelligence unit) found that the insurer had reported 44 suspicious transactions from February 2021 to March 2022, which it had internally classified as reportable, not within three business days but between 2 and 324 business days late, and had filed 28 reportable cash transactions from 2018 to 2022 between 1 and 552 days late. KoFIU imposed a fine of KRW 75.9 million on 10 October 2023.

What organisations can take from it

Deadlines for suspicious transaction reports run from the internal classification; processing backlogs are themselves a breach.

Relevance to training and awareness

Timely suspicious transaction and cash reports

Authority / court
Korea Financial Intelligence Unit (KoFIU)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Art. 4 Abs. 1 und Art. 4-2 Abs. 1 Act on Reporting and Using Specified Financial Transaction Information; Art. 8-2 Durchführungsverordnung
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
12 Oct 2023

Original amount 75,900,000 KRW, converted at the ECB reference rate of 10 Oct 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 10 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 USASuspicious activity reportsanonymised €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.

What organisations can take from it

Growing alert backlogs in transaction monitoring are a warning sign to which management and the board must respond with additional resources.

Relevance to training and awareness

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.

Sources

Checked against the official source on 7 Oct 2026 · Company name anonymised since 29 Sep 2025 · Direct link

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29 Sep 2023 a UK derivatives brokerFCA: £6.47 million against UK derivatives broker over outdated AML controls United KingdomInternal controlsanonymised €7.48m

The UK Financial Conduct Authority (FCA) imposed £6,470,600 (after a 30% discount) because, between September 2014 and October 2016, the derivatives broker had only a rudimentary customer risk assessment, no firm-wide money laundering risk assessment and no adequate ongoing monitoring; its policies referred to outdated legislation. The FCA had already raised concerns in 2014.

What organisations can take from it

Policies that refer to repealed legislation are a sure sign of a dead AML programme.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
FCA Principle 3; SYSC
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
50 to 249
Mitigating circumstances
30% settlement discount
Published
2 Oct 2023

Original amount 6,470,600 GBP, converted at the ECB reference rate of 29 Sep 2023.

Sources

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 29 Sep 2025 · Direct link

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28 Sep 2023 a German payment institutionBaFin fines payment institution €150,000 over identification and monitoring failures GermanyCustomer due diligenceanonymised €150,000

BaFin (German Federal Financial Supervisory Authority) imposed a fine of 150,000 EUR on a German payment institution because its supervisory and control measures were inadequate. Obligations to continuously monitor business relationships, to update customer data and to identify contracting parties were not met. The fine is final.

What organisations can take from it

Payment institutions, too, must back identification and ongoing customer monitoring with effective controls, or the company is liable for the supervisory gap.

Relevance to training and awareness

Identifying contracting parties and keeping customer data up to date

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 130 Abs. 1 OWiG i. V. m. bußgeldbewehrten Pflichten des GwG (Aktualisierung von Kundendaten, Identifizierung der Vertragspartner)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Liability of senior managers
The fine is based on a breach of the duty of supervision under § 130 OWiG (German Administrative Offences Act).
Published
28 Sep 2023

Checked against the official source on 2 Oct 2026 · Company name anonymised since 28 Sep 2025 · Direct link

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27 Sep 2023 a UAE payments fintechADGM: 486,000 USD fine for a payments fintech over AML failings and insurance sales United Arab EmiratesCustomer due diligenceanonymised €461,276

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the provider of prepaid cards and money transfers 486,000 USD. Between March 2021 and June 2022 its anti-money laundering policies, risk assessments, customer due diligence (for example on expected payment volumes and residential addresses) and monitoring of suspicious transactions were inadequate, with the risk assessment and due diligence failings affecting all 16,210 customers, and semi-annual reports of the money laundering reporting officer (MLRO) to the regulator were missing; in addition, from May 2021 to November 2022 the firm enrolled 1,956 customers in a group personal accident insurance scheme without the required permission. The regulator identified no specific instances of money laundering; without the 20% discount for early settlement the fine would have been 607,500 USD.

What organisations can take from it

When moving from a regulatory testing environment to full operation, AML controls and the scope of permissions must keep pace with the product range.

Relevance to training and awareness

Anti-money laundering controls as a fintech grows

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Sections 17(1) und 232 FSMR 2015; AML Rules 4.1.1(1), 4.1.1(2)(a) und (d), 4.1.1(4), 6.1.1, 6.2.1(b)(i), 7.1.1(3)(b) und (e), 8.3.1(1)(c), 8.3.2(2), 12.4.3, 14.2.1
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
No previous AML breaches, cooperation throughout including an independent third-party report, completed remediation (subject to verification by the regulator); 20% discount for early settlement.

Original amount 486,000 USD, converted at the ECB reference rate of 27 Sep 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 27 Sep 2025 · Direct link

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