Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.

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

Click a bar to drill down one level.

When?

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

293 cases

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

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

What organisations can take from it

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Ongoing due diligence and regular anti-money laundering training

Missing or inadequate training played a role in the decision.

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

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

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

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

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

What organisations can take from it

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Risk-based customer profiles and source of funds

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

KYC and transaction monitoring at payment service providers

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Financial vulnerability checks and AML controls in online betting

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money laundering obligations for accounting and advisory firms

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

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

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

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

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

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

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

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

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3 Aug 2026 UBS Financial Services Inc.FinCEN: 125 million USD against UBS Financial Services as a repeat offender USAInternal controls €108.4m

The US Financial Crimes Enforcement Network (FinCEN) imposed 125 million USD on the broker-dealer – the highest BSA penalty against a broker-dealer to date. UBSFS admitted wilful infringements: the AML programme was inadequate, more than 50,000 foreign currency transfers totalling more than 10 billion USD were not adequately monitored and suspicious activity reports were not filed; it is already the second enforcement action after 2018.

What organisations can take from it

Monitoring gaps left unremedied after an earlier enforcement action lead, the second time round, to a multiple of the original penalty.

Authority / court
Financial Crimes Enforcement Network (FinCEN)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Bank Secrecy Act (BSA)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Culpability
intentional
Repeat case
yes
Mitigating circumstances
Up to 15 million USD (remaining amount due by 31 May 2028) may be waived to the extent that UBSFS bears the costs of the independent review of its AML programme and implements its recommendations
Published
3 Aug 2026

Original amount 125,000,000 USD, converted at the ECB reference rate of 3 Aug 2026.

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money-laundering: investigating conspicuous inflows and documentation

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Compliance with cease-and-desist orders and KYC obligations

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Control over the distribution of own products to unlicensed operators

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Suspicious transaction reports even for merely attempted transactions

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Risk-based customer assessment in gambling

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Ongoing monitoring of business relationships and suspicious activity reporting

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer due diligence and suspicious transaction reports

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Register checks and follow-up on identified KYC gaps

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Enhanced due diligence for high-risk customers

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Licensing requirement and KYC for cross-border crypto services

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

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

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

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

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Internal controls in the AML programmes of crypto service providers

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Recognising unusual transactions and filing suspicious transaction reports without delay

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money laundering monitoring of foreign exchange with crypto intermediaries

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer due diligence and transaction monitoring for high-risk customers

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Recognising and reporting grounds for suspicion in crypto exchange

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Recognising structured deposits below the checking threshold

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Counterparty checks and customer identification for crypto transfers

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

What organisations can take from it

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

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

Original amount 51,562.5 CAD, converted at the ECB reference rate of 11 Mar 2026.

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

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6 Mar 2026 Canaccord Genuity LLCFinCEN: 80 million USD against Canaccord Genuity over AML and correspondent banking deficiencies USACustomer due diligence €69.2m

The US Financial Crimes Enforcement Network (FinCEN) imposed 80 million USD on the broker-dealer, which admitted wilful BSA infringements: no effective AML programme, no due diligence on correspondent accounts of foreign financial institutions and failure to file suspicious activity reports in connection with securities fraud. Remedial measures that had been promised were not implemented for years.

What organisations can take from it

Implement remedial measures promised in writing to the supervisory authority genuinely and swiftly – years of delay aggravate the later sanction.

Authority / court
Financial Crimes Enforcement Network (FinCEN)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Bank Secrecy Act (BSA)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Published
6 Mar 2026

Original amount 80,000,000 USD, converted at the ECB reference rate of 6 Mar 2026.

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

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5 Mar 2026 Stonehage Fleming Luxembourg S.A.Stonehage Fleming Luxembourg: EUR 56,000 for late suspicious activity reports LuxembourgSuspicious activity reports €56,000

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

What organisations can take from it

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

Relevance to training and awareness

Investigating adverse media and reporting completely and on time

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

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

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

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

What organisations can take from it

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

AML training for existing and new staff

Missing or inadequate training played a role in the decision.

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Identifying beneficial owners in holding and trust structures

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Risk classification of cash-intensive high-risk sectors

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Cash transactions in luxury retail, structuring and staff involvement

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

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

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10 Feb 2026 Paxful Holdings Inc.Crypto platform Paxful: 4 million USD penalty after guilty plea to BSA infringements USAInternal controls €3.36m

Following a guilty plea to charges including conspiracy to operate an unlicensed money transmitting business and to violate the AML obligations of the Bank Secrecy Act, the peer-to-peer crypto platform was sentenced to a penalty of 4 million USD. 112.5 million USD would have been appropriate, but the US Department of Justice (DOJ) found an inability to pay; in December 2025, FinCEN had additionally imposed a civil penalty of 3.5 million USD.

What organisations can take from it

Crypto platforms without registration and KYC face criminal liability – up to the limit of their ability to pay.

Authority / court
U.S. Department of Justice
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Travel Act; Verschwörung zum Betrieb eines nicht lizenzierten Geldtransfergeschäfts und zur Verletzung der AML-Pflichten des Bank Secrecy Act
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Mitigating circumstances
Penalty limited from 112.5 million to 4 million USD because of proven inability to pay
Published
11 Feb 2026

Original amount 4,000,000 USD, converted at the ECB reference rate of 10 Feb 2026.

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

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

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

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

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

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

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

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

What organisations can take from it

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Money laundering risk assessment by employees

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Money laundering risk management at trust and company service providers

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Timely regulatory returns to the supervisor

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer due diligence and customer risk rating

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Identification for cash payments in the trade in goods

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Business profiles and handling conflicts of interest in the trust business

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Identifying personal accounts used for business purposes

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer identification (KYC) at crypto exchanges

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

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

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

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9 Dec 2025 Paxful, Inc. und Paxful USA, Inc.FinCEN: USD 3.5 million against crypto platform Paxful for failing to register and AML failures USAInternal controls €3.01m

FinCEN imposed a civil money penalty of USD 3.5 million on the peer-to-peer virtual currency trading platform Paxful, Inc. and Paxful USA, Inc. From February 2015 to April 2023 Paxful did not maintain an effective AML programme for its trading platform and hosted wallets and did not report suspicious transactions accurately and on time; the company also allowed its registration as a money services business to lapse and operated unregistered from January 2017 to September 2019 (974 days). Payments of USD 1.75 million to the DOJ are credited against the penalty; USD 1.75 million is payable to FinCEN. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Crypto marketplaces must ensure registration, including timely renewal, customer due diligence and suspicious activity reporting from the outset and keep them in step with growth.

Relevance to training and awareness

AML duties of crypto platforms: registration, KYC and suspicious activity reporting

Authority / court
Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
31 U.S.C. § 5330, § 5318(h)(1), § 5318(g)(1); 31 C.F.R. §§ 1022.380, 1022.210, 1022.320
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
FinCEN took into account that Paxful was forthcoming during the investigation, answered information requests completely and on time and agreed to toll the statute of limitations.

Original amount 3,500,000 USD, converted at the ECB reference rate of 9 Dec 2025.

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Detecting suspicious cheque and cash flows at branches

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

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

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

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

AML training programme for estate agents

Missing or inadequate training played a role in the decision.

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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20 Nov 2025 Caesars Entertainment, Inc. / Desert Palace, LLC (Caesars Palace)Nevada: 7.8 million USD against Caesars over gambling by an illegal bookmaker USA, NVCustomer due diligence €6.77m

On 13 November 2025, the Nevada Gaming Control Board (NGCB) filed a disciplinary complaint for unsuitable methods of operation in connection with an illegal bookmaker and at the same time concluded a settlement of 7.8 million USD with conditions attached to the gaming licences. The conditions relate primarily to improving the AML programme and to additional training and awareness-raising for employees; the Nevada Gaming Commission (NGC) adopted the settlement as its order on 20 November 2025 (Case No. 25-03).

What organisations can take from it

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

Relevance to training and awareness

Checking the source of gambling funds, recognising high-risk customers

Missing or inadequate training played a role in the decision.

Authority / court
Nevada Gaming Commission (NGC) auf Beschwerde des Nevada Gaming Control Board (NGCB)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Glücksspielrecht Nevada (unsuitable methods of operation)
Action
Fine
Status of proceedings
final
Sector
Other
Employees
10,000 or more
Mitigating circumstances
Numerous remedial measures already implemented
Published
13 Nov 2025

Original amount 7,800,000 USD, converted at the ECB reference rate of 20 Nov 2025.

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

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

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

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Negative media reports as a trigger for suspicious transaction reports

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

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

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

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

What organisations can take from it

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

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

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

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

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

What organisations can take from it

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer identification and mandatory training at foreign exchange dealers

Missing or inadequate training played a role in the decision.

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

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

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

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

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

What organisations can take from it

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Money laundering risks in the gambling environment

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Filing money laundering suspicious activity reports without delay

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Client risk rating and ongoing and enhanced due diligence

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Registration requirements for cryptoasset services

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Name and sanctions screening: resolving and documenting alerts

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Suspicious activity reports and handling of high-risk transactions

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money laundering and PEP clients

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer due diligence and adverse media screening

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

AML programme, licence boundaries and disclosure to the regulator

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

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

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

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

What organisations can take from it

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

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

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

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

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31 Jul 2025 Gomti ExchangeCBUAE revokes Gomti Exchange's licence over AML and sanctions failings United Arab EmiratesInternal controls Other

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

What organisations can take from it

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

Relevance to training and awareness

AML and sanctions compliance at exchange houses

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

AML and sanctions compliance in exchange houses

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

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

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

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

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

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

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

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

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

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

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

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

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

Relevance to training and awareness

Misrepresentation of licensing status and AML obligations

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

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

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

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

What organisations can take from it

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

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

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

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22 Jul 2025 Indian Overseas Bank, Hong Kong BranchIndian Overseas Bank (Hong Kong): HKD 8.5m penalty and orders over monitoring failings Hong KongInternal controls €925,553

The Hong Kong branch of Indian Overseas Bank was reprimanded, ordered to pay a pecuniary penalty of 8,500,000 HKD and required to carry out a look-back review of its transaction-monitoring alerts, submit a remedial plan and have its effectiveness assessed by an external adviser. Between May 2021 and January 2024 alerts were not properly followed up, unusual transactions of ten customers were not examined and documented, and senior management did not steer anti-money laundering controls effectively; a competent compliance officer, clear responsibilities and adequate training were lacking.

What organisations can take from it

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

Relevance to training and awareness

Handling monitoring alerts and senior management responsibility for anti-money laundering

Missing or inadequate training played a role in the decision.

Authority / court
Hong Kong Monetary Authority (HKMA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
s. 21(2)(a), (b), (c) AMLO (Cap. 615); Schedule 2 ss. 5(1)(c), 19(3), 23 AMLO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
No previous disciplinary record under the AMLO, cooperation with the regulator.
Liability of senior managers
The regulator found that senior management did not take a clear leadership role in anti-money laundering and did not appoint a competent compliance officer; the decision contains no measures against individuals.
Published
22 Jul 2025

Original amount 8,500,000 HKD, converted at the ECB reference rate of 22 Jul 2025.

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

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22 Jul 2025 33 Financial Services LimitedHKMA: reprimand and HKD 1.6m for 33 Financial Services over gift card failures Hong KongCustomer due diligence €174,222

The HKMA reprimanded the licensed stored value facility provider 33 Financial Services and ordered it to pay a pecuniary penalty of HKD 1.6 million. Between December 2019 and August 2023, a group made up of one corporate and five individual customers bought more than 49,000 gift cards for around HKD 25 million without the firm sufficiently establishing the purpose and nature of the business relationship; for ten customers whom it knew to be buying on behalf of businesses, those businesses were not subjected to due diligence. The firm also failed to ensure that business partners verified and documented the identity of non-Hong Kong resident customers in person.

What organisations can take from it

Gift cards are no exception: anyone evidently buying for a business brings that business in as a customer, and outsourced identity checks must be monitored.

Relevance to training and awareness

Customer due diligence when selling gift and stored value cards

Authority / court
Hong Kong Monetary Authority (HKMA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Sections 33Q(2)(a) und 33Q(2)(b)(iii), Section 8Q Payment Systems and Stored Value Facilities Ordinance (Cap. 584) i. V. m. Section 6(2)(b) Part 2 Schedule 3; Guideline on AML/CFT (For Stored Value Facility Licensees)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
Remedial measures to improve controls and cooperation with the HKMA.
Published
22 Jul 2025

Original amount 1,600,000 HKD, converted at the ECB reference rate of 22 Jul 2025.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Implementing supervisory AML instructions in banks

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

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

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

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9 Jul 2025 Wise US, Inc.Six US states: 4.2 million USD against Wise US over AML programme deficiencies USA, NYSuspicious activity reports €3.59m

In a coordinated multistate proceeding brought by six states – the New York State Department of Financial Services (NYDFS) with the supervisory authorities of CA, MN, NE, TX and MA – the money transmitter must pay 4.2 million USD. An examination (July 2022 to September 2023) found, among other things, a lack of independent AML reviews at an appropriate frequency, late suspicious activity reports, data quality problems in transaction monitoring and unremedied earlier findings; Wise does not admit any legal infringements and must conduct a lookback.

What organisations can take from it

Remedy findings from earlier examinations and audits on time – otherwise they become a ground for sanctions in their own right.

Authority / court
New York State Department of Financial Services (NYDFS) mit den Aufsichtsbehörden von CA, MN, NE, TX und MA
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Bundes- und einzelstaatliches Recht zu Geldtransfer und BSA/AML (u. a. 31 CFR 1022.320)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Remedial measures already initiated and lookback
Published
9 Jul 2025

Original amount 4,200,000 USD, converted at the ECB reference rate of 9 Jul 2025.

Sources

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Ongoing monitoring of existing customer relationships

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Plausibility checks in customer onboarding

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Identification for cash deposits by non-customers

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money laundering in branches of foreign institutions

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer due diligence and complete information on cross-border transfers

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

Missing or inadequate training played a role in the decision.

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

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

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

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

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

What organisations can take from it

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Recognising cash as a risk factor

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

AML obligations in the art trade

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

AML obligations of exchange houses

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

High-risk clients and transaction monitoring

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer identification (KYC)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

AML frameworks at exchange houses

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Suspicious activity reporting for counterfeit goods trading through payment accounts

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Risk rating of clients and beneficial owners

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Complying with specific licence conditions imposed after earlier cases

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

AML duties of audit firms as DNFBPs

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Suspicious activity reporting and source-of-funds checks

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Enhanced due diligence on politically exposed persons

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Ongoing monitoring and immediate reporting of unusual transactions

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

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

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