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

Sources

Finantsinspektsioon tegi Wallester AS-ile ettekirjutuse (16.09.2026) Press release of an authority

Checked against the official source on 25 Sep 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

Sources

Settlement Agreement Publication Notice – EM@NEY P.L.C. Decision of an authority

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

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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20 Aug 2026 Tax adviser uses firm's account for third-party payments: 30,000 EUR FMA penalty upheld AustriaCustomer due diligence €30,000

From December 2022, an auditor and tax adviser processed payments of another limited company totalling around 1.26 million EUR through the bank account of his tax advisory company, which was held as an own account, without disclosing this to the bank – according to the court, deliberately in order to avoid a compliance review. The Austrian Federal Administrative Court (Bundesverwaltungsgericht, BVwG) upheld the fine of 30,000 EUR imposed on him by the Financial Market Authority (Finanzmarktaufsicht, FMA) in its penalty decision of 27 November 2025, in his capacity as managing director of the account-holding company, which is liable for the penalty; an ordinary appeal on points of law is not admissible.

What organisations can take from it

Customers also have obligations under anti-money laundering law: anyone channelling third-party funds through an own account must disclose this to the bank.

Relevance to training and awareness

Disclosure obligations as a bank customer for trust and pass-through payments

Authority / court: Bundesverwaltungsgericht (BVwG); Straferkenntnis der Finanzmarktaufsicht (FMA) vom 27.11.2025
Area of law: Money laundering and terrorist financing · Customer due diligence
Legal basis: § 6 Abs. 3 FM-GwG (Offenlegung des Handelns auf fremde Rechnung) i. V. m. § 34 Abs. 5 FM-GwG; § 9 Abs. 1 und 7 VStG
Action: Fine
Status of proceedings: final
Sector: Other
Culpability: intentional
Liability of senior managers: Fine imposed on the managing director personally; liability of the company under Section 9(7) VStG (Austrian Administrative Penal Act)

Sources

BVwG W607 2331234-1 vom 20.08.2026 Court decision

Checked against the official source on 25 Sep 2026 · 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.

Sources

FinCEN Assesses Historic $125 Million Penalty Against UBS Financial Services Inc. for Recidivist BSA Violations Press release of an authority
FinCEN Consent Order Imposing Civil Money Penalty – UBS Financial Services Inc. (Number 2026-02) Decision of an authority
FinCEN Enforcement Actions Enforcement database of an authority

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

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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.

Sources

FINTRAC imposes an administrative monetary penalty on Nova Scotia Gaming Corporation Press release of an authority
Public notice of administrative monetary penalties Enforcement database 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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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.

Sources

FINTRAC imposes an administrative monetary penalty on 13010431 Canada Inc. Press release of an authority
Public notice of administrative monetary penalties Enforcement database 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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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.

Sources

FINTRAC imposes an administrative monetary penalty on Birks Group Inc. Press release of an authority
Public notice of administrative monetary penalties 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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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

Sources

Administrative Measure Publication Notice – BNF Bank p.l.c. Decision of an authority

Checked against the official source on 25 Sep 2026 · 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

FINMA-Verfahren: MBaer Merchant Bank AG in Liquidation Press release of an authority
Massnahmen bei MBaer Merchant Bank AG Press release 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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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.

Sources

Virtual Asset Trading Platform Sentenced for Violating the Travel Act and Other Federal Criminal Charges Press release of an authority
FinCEN Assesses $3.5 Million Penalty Against Paxful for Facilitating Suspicious Activity Involving Illicit Actors Press release of an authority
FinCEN Consent Order Imposing Civil Money Penalty – Paxful, Inc. and Paxful USA, Inc. (Number 2025-02) Decision of an authority

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

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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

Fine for CCV Group B.V. for lack of SIRA Press release of an authority

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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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.

Sources

FINTRAC imposes an administrative monetary penalty on Manor Windsor Realty Ltd. Press release of an authority
Public notice of administrative monetary penalties Enforcement database 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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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

Enforcement Action against Coinbase Europe Limited Press release of an authority

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

Sources

Mangelhafte Geldwäscheprävention: BaFin setzt Bußgeld gegen die Landesbank Hessen-Thüringen Girozentrale fest Press release of an authority
Bekanntmachung zur Landesbank Hessen-Thüringen Girozentrale Official register or notice

Checked against the official source on 25 Sep 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.

Sources

FINTRAC imposes an administrative monetary penalty on Xeltox Enterprises Ltd. Press release of an authority
Public notice of administrative monetary penalties Enforcement database 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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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

Sources

Mängel in der Geldwäscheprävention: Bußgeld in Höhe von 45 Millionen Euro gegen J.P. Morgan SE Press release of an authority
Bekanntmachung zur J.P. Morgan SE (§ 57 GwG) Official register or notice

Checked against the official source on 25 Sep 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

Sources

Varengold Bank AG: BaFin ordnet umfassende Mängelbeseitigung in der Geldwäscheprävention an und setzt Geldbuße fest Press release of an authority
Bekanntmachungen zur Varengold Bank AG (§ 57 GwG) Official register or notice

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. A former asset manager was separately given a suspended prison sentence.

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.
Liability of senior managers: A former asset manager was separately given a suspended prison sentence of six months for aggravated money laundering (offences committed at another Swiss bank).
Published: 22 Aug 2025

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

Sources

Bundesanwaltschaft verurteilt Bank J. Safra Sarasin AG (Strafbefehl) 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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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.

Sources

FINTRAC imposes an administrative monetary penalty on DMCL Chartered Professional Accountants Press release of an authority
Public notice of administrative monetary penalties Enforcement database of an authority

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

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9 Jul 2025 Wise US, Inc.Six US states: 4.2 million USD against Wise US over AML programme deficiencies 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

Consent Order – Wise US, Inc. (Multi-State) Decision of an authority

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

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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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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

Sources

Banca Privata Leasing Spa – Provvedimento n. 197 del 24 giugno 2025 (AML) Decision 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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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

Sources

Bekanntmachungen gemäß § 57 GwG – Landesdirektion Sachsen (lfd. Nr. 36) Official register or notice

Checked against the official source on 25 Sep 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, an asset manager at the bank validated 54 transfers through 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, and the former employee received a suspended prison sentence.

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.
Liability of senior managers: Former asset manager: suspended prison sentence of six months (probation period of two years).
Published: 17 Jun 2025

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

Sources

Banque Pictet et Cie SA und ehemaliger Vermögensverwalter per Strafbefehl verurteilt Press release 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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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

Sources

Administrative Measure Publication Notice – OKCoin Europe Limited Decision of an authority

Checked against the official source on 25 Sep 2026 · 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

Sources

Razkritje informacij o izrečenem ukrepu subjektu nadzora – MAKI d.o.o. Koper Decision of an authority
Banka Slovenije – Informacije o izrečenih ukrepih Enforcement database of an authority

Checked against the official source on 25 Sep 2026 · 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.

Sources

Bundesanwaltschaft schliesst Strafuntersuchung gegen Morgan Stanley (Switzerland) GmbH mit Strafbefehl ab 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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9 Jan 2025 Arian Financial LLPFCA: small broker Arian Financial 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
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.

Sources

FCA fines Arian Financial LLP for failings relating to cum-ex trading Press release of an authority
2025 fines | FCA Enforcement database of an authority
Final Notice: Arian Financial LLP (09.01.2025) Decision of an authority

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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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.

Sources

FinCEN Assesses $900,000 Civil Money Penalty Against Lake Elsinore Hotel and Casino for Violations of the Bank Secrecy Act Press release of an authority
FinCEN Consent Order – Sahara Dunes Casino, LP d/b/a Lake Elsinore Hotel and Casino (Number 2024-03) Decision of an authority
FinCEN Enforcement Actions Enforcement database of an authority

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

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

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

What organisations can take from it

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

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

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

Sources

Federal Reserve Board fines Toronto-Dominion Bank $123.5 million for violations related to anti-money laundering laws Press release 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 Apr 2024 N26 Bank AGBaFin: 9.2 million EUR against N26 over systematically late suspicious activity reports GermanySuspicious activity reports €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

Sources

Geldwäscheprävention: BaFin setzt Geldbuße gegen N26 Bank AG fest Press release of an authority
Bekanntmachung zur N26 Bank AG (§ 57 GwG) Official register or notice

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

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25 Mar 2024 Banque Audi (Suisse) SAFINMA confiscates 3.9 million CHF in profits from Banque Audi (Suisse) SwitzerlandSuspicious activity reports €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

FINMA-Verfahren: Banque Audi (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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10 Jan 2024 Lombard International Assurance S.A.Lombard International Assurance: 1.68 million EUR over missing overall money laundering risk assessment LuxembourgInternal controls €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

Sources

CAA – Sanction administrative Lombard International Assurance S.A. (20.03.2024) Decision of an authority

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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21 Nov 2023 OTP Bank Nyrt.OTP Bank: 49.4 million HUF over late suspicious transaction reports HungarySuspicious activity reports €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.); Beschluss H-PM-I-B-76/2023
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.

Sources

Hiányosságok az OTP Bank pénzmosási bejelentési és belső ellenőrzési rendszerében 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	1	€7.48m
Q4 2023	3	€1.76m
Q1 2024	2	€5.69m
Q2 2024	3	€9.21m
Q3 2024	0	—
Q4 2024	3	€113.9m
Q1 2025	4	€1.41m
Q2 2025	7	€40.1m
Q3 2025	8	€61.7m
Q4 2025	9	€232.4m
Q1 2026	11	€75.3m
Q2 2026	3	€12.9m
Q3 2026	8	€109.1m

Who was sanctioned, and for what?

Where?

What for?

Who?

When?

62 cases

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