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

Sources

Settlement Agreement Publication Notice – MiFinity Malta Limited Decision of an authority

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

Sources

Administrative Measure Publication Notice – Goldwin Ltd Decision of an authority
Publication of AML/CFT Administrative Penalties and Measures – FIAU Enforcement database of an authority

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

Sources

Volksbank Düsseldorf Neuss eG: Bafin setzt Bußgelder fest Press release of an authority
Bekanntmachung zur Volksbank Düsseldorf Neuss eG (§ 57 GwG) Official register or notice

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

Sources

Banca Popolare Commerciale Spa – Provvedimento n. 190 del 23 giugno 2026 (AML) Decision of an authority

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

Final Notice 2026: CACEIS Bank (UK Branch) Decision of an authority

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.

Sources

FI ger Ikano Bank en anmärkning och en sanktionsavgift (17.06.2026) Press release of an authority

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

Administrative Measure Publication Notice – Stanleybet Malta Limited Decision of an authority
Administrative Measures – FIAU Enforcement database of an authority

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

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6 Mar 2026 Canaccord Genuity LLCFinCEN: 80 million USD against Canaccord Genuity over AML and correspondent banking deficiencies 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.

Sources

FinCEN Assesses Historic $80 Million Penalty Against Canaccord Genuity LLC for Securities Fraud-Related Bank Secrecy Act Violations Press release of an authority
FinCEN Consent Order Imposing Civil Money Penalty – Canaccord Genuity LLC (Number 2026-01) Decision of an authority

Checked against the official source on 25 Sep 2026 · 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

Sources

BVwG W204 2306222-1 vom 20.02.2026 Court decision

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

Sources

BVwG W204 2304676-1 vom 17.02.2026 Court decision

Checked against the official source on 25 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

Sources

CAA – Sanction administrative Cardif Lux Vie S.A. (01.07.2026) Decision of an authority
CAA – Sanctions et autres mesures administratives Enforcement database of an authority

Checked against the official source on 25 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). Karl-Ernst Hardeck is named as the person responsible for the company.

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: The announcement names Karl-Ernst Hardeck as the person responsible for the infringement

Sources

Bekanntmachung nach § 57 GwG – Bezirksregierung Arnsberg Official register or notice

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

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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.

Sources

FCA fines Nationwide £44m for failings in financial crime controls Press release of an authority
2025 fines | FCA Enforcement database of an authority
Final Notice: Nationwide Building Society (11.12.2025) Decision of an authority

Checked against the official source on 25 Sep 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 the illegal bookmaker Mathew Bowyer 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.

Sources

Nevada Gaming Control Board and Caesars Entertainment, Inc. Enter into Proposed Stipulation for Settlement Regarding Disciplinary Complaint Press release of an authority
Nevada Gaming Commission – Disposition, November 2025 Agenda (20.11.2025) Decision of an authority

Checked against the official source on 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.

Sources

Zimpler får en anmärkning och sanktionsavgift (15.10.2025) Press release of an authority

Checked against the official source on 25 Sep 2026 · 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.

Sources

Fall 1MDB: Bank JP Morgan Suisse mit Strafbefehl verurteilt Press release of an authority

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

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

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

What organisations can take from it

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

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

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

Sources

In the Matter of Paxos Trust Company, LLC – Consent Order Decision of an authority

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

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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.

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
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.

Sources

FCA fines Monzo £21m for failings in financial crime controls Press release of an authority
2025 fines | FCA Enforcement database of an authority
Final Notice: Monzo Bank Limited (07.07.2025) Decision of an authority

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

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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

Sources

The Central Bank takes enforcement action against Swilly Mulroy Credit Union for breaches of Anti-Money Laundering requirements Press release of an authority

Checked against the official source on 25 Sep 2026 · 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

Sources

Administrative Measure Publication Notice – C2D Payment Solutions Limited Decision of an authority

Checked against the official source on 25 Sep 2026 · 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

Sources

Finanssivalvonta – LocalBitcoins Oy:lle 500 000 euron seuraamusmaksu (3.6.2025) Press release of an authority
Finanssivalvonta – Hallinnolliset seuraamukset (Übersicht mit Rechtskraftvermerk) Enforcement database of an authority

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

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10 Apr 2025 Block, Inc.NYDFS: 40 million USD against Block (Cash App) over AML deficiencies 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.

Sources

Superintendent Adrienne A. Harris Secures $40 Million Settlement with Block, Inc. for Inadequate Anti-Money Laundering Program and Virtual Currency Compliance Failures on Cash App Platform Press release of an authority

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

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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

Sources

Bekanntmachungen gemäß § 57 GwG – Landesdirektion Sachsen (lfd. Nr. 29) Official register or notice

Checked against the official source on 25 Sep 2026 · 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

Sources

Administrative Measure Publication Notice – Integritas Consulting Ltd Decision of an authority

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

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18 Jun 2024 HSBC Private Bank (Suisse) SAFINMA: HSBC Private Bank (Suisse) breached anti-money laundering rules for two PEPs SwitzerlandCustomer due diligence 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

FINMA-Verfahren: HSBC Private Bank (Suisse) SA hat gegen Geldwäschereiregeln verstossen Press release of an authority

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

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5 Jun 2024 CarXclusive GmbHCar dealer CarXclusive: 12,866 EUR fine for breach of AML due diligence obligations GermanyCustomer due diligence €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

Sources

Bekanntmachung nach § 57 GwG – Bezirksregierung Arnsberg Official register or notice

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

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24 Nov 2023 UAB „Finansinės paslaugos „Contis““Contis: 840,000 EUR for anti-money laundering delegated to partners without oversight LithuaniaCustomer due diligence €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. Source: archived copy of the press release.

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

Sources

Lietuvos bankas, Pranešimas 2023-11-24 (Archivkopie web.archive.org von lb.lt) Press release of an authority

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

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Period	Cases	Total
Q3 2023	0	—
Q4 2023	1	€840,000
Q1 2024	0	—
Q2 2024	2	€12,866
Q3 2024	0	—
Q4 2024	1	€66,504
Q1 2025	1	€800
Q2 2025	3	€36.8m
Q3 2025	4	€50.5m
Q4 2025	4	€57.8m
Q1 2026	5	€71m
Q2 2026	3	€12.9m
Q3 2026	3	€451,006

Who was sanctioned, and for what?

Where?

What for?

Who?

When?

27 cases

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