Who was sanctioned, and for what?

From 2016 to 2025, the operator of the OTC Link ATS trading system lacked complete policies on systems security, access control and vulnerability management as required under Regulation SCI. Although the examiners of the U.S. Securities and Exchange Commission (SEC) had criticised the gaps in several examinations, drafts remained unfinished; the SEC issued a censure and imposed 575,000 USD.

Authority / court

U.S. Securities and Exchange Commission (SEC)

Area of law

Information security and cyber · Critical infrastructure

Legal basis

Regulation SCI, Rule 1001(a)(1)–(3)

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Repeat case

yes

Original amount 575,000 USD, converted at the ECB reference rate of 22 Sep 2026.

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

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In 2023, a federal court found by way of summary judgment that the fuel card provider had charged its predominantly small business customers hidden or unauthorised fees and misrepresented savings; an appeals court upheld this in 2026. According to the FTC, the fees added up to hundreds of millions of dollars, and late fees were also charged despite punctual payment. Under the settlement resolving the administrative proceedings, FleetCor and CEO Ronald Clarke are paying 100 million USD for refunds; the order is not yet final.

Authority / court

Federal Trade Commission (FTC)

Area of law

Consumer protection and online retail · Misleading advertising and pricing

Legal basis

Section 5 FTC Act

Action

Disgorgement of profits

Status of proceedings

unknown

Sector

Financial services and insurance

Liability of senior managers

CEO Ronald Clarke is named in the press release as a party involved.

Published

17 Sep 2026

Original amount 100,000,000 USD, converted at the ECB reference rate of 17 Sep 2026.

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

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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.

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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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.

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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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.

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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In 2017/2018, the Chicago fund manager specialising in data centres took in capital from the Russian oligarch Suleiman Kerimov via nested structures and continued to manage this investment for four years after his designation in April 2018. The US Treasury's Office of Foreign Assets Control (OFAC) assessed the case as non-egregious and not voluntarily self-disclosed.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Ukraine-/Russia-Related Sanctions Regulations (31 C.F.R. part 589); IEEPA

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

No prior violations in five years; cooperation improved significantly only after initially insufficient engagement (including waiver of attorney-client privilege), hence only limited credit

Published

2 Dec 2025

Original amount 11,485,352 USD, converted at the ECB reference rate of 2 Dec 2025.

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

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From 2017 to 2022, the Indian subsidiary Liberty General Insurance paid around 1.47 million USD to employees of six state-owned banks so that they would refer bank customers to its insurance products; the payments were booked as marketing expenses and routed through third parties. The DOJ declined to prosecute; Liberty Mutual is disgorging 4,699,088 USD in profits.

Authority / court

U.S. Department of Justice (Fraud Section; USAO District of Massachusetts)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

FCPA, 15 U.S.C. § 78dd-2; Corporate Enforcement and Voluntary Self-Disclosure Policy (Declination)

Action

Disgorgement of profits

Status of proceedings

final

Sector

Financial services and insurance

Employees

10,000 or more

Culpability

intentional

Mitigating circumstances

Voluntary self-disclosure (March 2024), full cooperation, root cause analysis, termination of those involved, improved controls including rules on messaging apps.

Published

7 Aug 2025

Original amount 4,699,088 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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Employees identified weaknesses in investment models that could affect client returns by March 2019 at the latest, but Two Sigma only acted in August 2023; there were no policies, and one employee made unauthorised changes to more than a dozen models. In addition, separation agreements required employees to declare that they had not filed any complaint with authorities. The U.S. Securities and Exchange Commission (SEC) imposed 90 million USD; Two Sigma had already repaid 165 million USD to clients.

Authority / court

U.S. Securities and Exchange Commission (SEC)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Investment Advisers Act of 1940 (Antifraud, Compliance Rule 206(4)-7); Exchange Act Rule 21F-17(a)

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Culpability

intentional

Mitigating circumstances

Voluntary repayment of 165 million USD to affected funds and accounts.

Original amount 90,000,000 USD, converted at the ECB reference rate of 16 Jan 2025.

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

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From December 2020 to May 2023, staff on the agency CMO bond desk sold mortgage-backed bonds worth around 3 billion USD using misleading metrics; the broker-dealer’s supervisory procedures contained no requirements for the structuring and sale of these bonds. BMO paid 19,417,908 USD in disgorgement, 2,241,507 USD in interest and a civil penalty of 19 million USD.

Authority / court

U.S. Securities and Exchange Commission (SEC)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Securities Exchange Act of 1934, Section 15(b)(4)(E) (Failure to supervise)

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Employees

10,000 or more

Original amount 40,659,415 USD, converted at the ECB reference rate of 13 Jan 2025.

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

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From 2020 to 2022, Invesco told clients that 70 to 94 per cent of the parent company's assets under management were ‘ESG integrated’, but counted passive ETFs that did not take ESG into account and had no written definition of ESG integration. The U.S. Securities and Exchange Commission (SEC) imposed 17.5 million USD, a censure and a cease-and-desist order.

Authority / court

U.S. Securities and Exchange Commission (SEC)

Area of law

Environment and sustainability · Misleading environmental and sustainability claims

Legal basis

Investment Advisers Act of 1940

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Culpability

intentional

Published

8 Nov 2024

Original amount 17,500,000 USD, converted at the ECB reference rate of 8 Nov 2024.

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

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

Authority / court

Board of Governors of the Federal Reserve System

Area of law

Money laundering and terrorist financing · Internal controls

Legal basis

US-Anti-Geldwäschegesetze (laut Federal Reserve)

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Employees

10,000 or more

Liability of senior managers

Independent review of board and management ordered

Published

10 Oct 2024

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

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

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The swap trading platform did not fully inform its board of the results of emergency, technology risk and penetration tests, did not regularly test its business continuity and disaster recovery capabilities and had no adequate risk management. It also failed to produce documents requested during an examination on time despite extensions of deadlines; the Commodity Futures Trading Commission (CFTC) imposed 875,000 USD.

Authority / court

Commodity Futures Trading Commission (CFTC)

Area of law

Information security and cyber · Critical infrastructure

Legal basis

Commodity Exchange Act; CFTC-Regeln zu System Safeguards für Swap Execution Facilities

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Original amount 875,000 USD, converted at the ECB reference rate of 1 Oct 2024.

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

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The asset manager had twelve job applicants sign NDAs that prohibited voluntary reports to authorities, and, in a settlement agreement, required a former employee who had announced a report to the SEC to confirm that he had not initiated any investigation and to withdraw statements already made. The U.S. Securities and Exchange Commission (SEC) took cooperation and remediation into account and imposed 500,000 US dollars.

Authority / court

U.S. Securities and Exchange Commission

Area of law

Whistleblower protection · Retaliation against whistleblowers

Legal basis

Securities Exchange Act of 1934, Rule 21F-17(a); Investment Advisers Act Section 203(e)

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Employees

50 to 249

Mitigating circumstances

Cooperation with the SEC and prompt remedial measures

Published

26 Sep 2024

Original amount 500,000 USD, converted at the ECB reference rate of 26 Sep 2024.

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

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Between May 2019 and September 2023, TransUnion had senior employees waive potential awards for reports to authorities in 29 severance, separation and incentive agreements; three consulting agreements prohibited voluntary disclosures to authorities. As part of a sweep against seven listed companies, TransUnion paid 312,000 US dollars to the U.S. Securities and Exchange Commission (SEC); the contract templates were amended.

Authority / court

U.S. Securities and Exchange Commission

Area of law

Whistleblower protection · Retaliation against whistleblowers

Legal basis

Securities Exchange Act of 1934, Rule 21F-17(a)

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

Amendment of the templates after contact by the SEC, information provided to those affected, and cooperation

Published

9 Sep 2024

Original amount 312,000 USD, converted at the ECB reference rate of 9 Sep 2024.

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

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From May 2021 to February 2024, the three New Jersey firms had eleven retail clients sign confidentiality agreements in connection with settlement payments that permitted reports to the SEC only at the SEC's initiative; in some cases, clients had to confirm that they had never contacted and would never contact authorities. Penalties imposed by the U.S. Securities and Exchange Commission (SEC): 160,000 (NPA Asset Management), 70,000 (Nationwide Planning) and 10,000 US dollars (Blue Point).

Authority / court

U.S. Securities and Exchange Commission

Area of law

Whistleblower protection · Retaliation against whistleblowers

Legal basis

Securities Exchange Act of 1934, Rule 21F-17(a)

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

4 Sep 2024

Original amount 240,000 USD, converted at the ECB reference rate of 4 Sep 2024.

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

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In April 2021, a third party alerted ICE to a vulnerability in its VPN; ICE found malicious code that had been inserted but did not inform the legal and compliance officers of its exchange and clearing subsidiaries for days. As a result, the subsidiaries, including the New York Stock Exchange, did not immediately report the incident to the U.S. Securities and Exchange Commission (SEC) as required under Regulation SCI; ICE paid 10 million USD.

Authority / court

U.S. Securities and Exchange Commission (SEC)

Area of law

Information security and cyber · Incident reporting obligations

Legal basis

Regulation Systems Compliance and Integrity (Regulation SCI), Meldepflichten

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Employees

10,000 or more

Repeat case

yes

Original amount 10,000,000 USD, converted at the ECB reference rate of 22 May 2024.

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

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From 2019 to 2023, the investment adviser claimed to use AI and machine learning to analyse client data for investment decisions but did not have these capabilities. In a settlement with the U.S. Securities and Exchange Commission (SEC) (without admission), Delphia paid 225,000 US dollars.

Authority / court

U.S. Securities and Exchange Commission

Area of law

AI and digital regulation · AI systems

Legal basis

Investment Advisers Act of 1940; Marketing Rule

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

18 Mar 2024

Original amount 225,000 USD, converted at the ECB reference rate of 18 Mar 2024.

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

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In 2023, the investment adviser falsely advertised itself as the ‘first regulated AI financial advisor’ offering AI-driven expert forecasts, misrepresented tax-loss harvesting and used impermissible liability clauses. In a settlement with the U.S. Securities and Exchange Commission (SEC), the company paid 175,000 US dollars.

Authority / court

U.S. Securities and Exchange Commission

Area of law

AI and digital regulation · AI systems

Legal basis

Investment Advisers Act of 1940; Marketing Rule

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

18 Mar 2024

Original amount 175,000 USD, converted at the ECB reference rate of 18 Mar 2024.

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

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From March 2020 to July 2023, JPMS had hundreds of retail clients who received credits or settlement payments of more than 1,000 US dollars sign confidentiality agreements that permitted responses to SEC enquiries but prohibited voluntary contact with the SEC. The U.S. Securities and Exchange Commission (SEC) imposed 18 million US dollars.

Authority / court

U.S. Securities and Exchange Commission

Area of law

Whistleblower protection · Retaliation against whistleblowers

Legal basis

Securities Exchange Act of 1934, Rule 21F-17(a)

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Employees

10,000 or more

Published

16 Jan 2024

Original amount 18,000,000 USD, converted at the ECB reference rate of 16 Jan 2024.

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

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From 2018 until the end of 2021, the Deutsche Bank subsidiary presented ESG as part of its ‘DNA’ but did not implement the ESG integration policies it had promised. It is paying 19 million USD for the ESG misstatements; in separate proceedings over deficiencies in its anti-money laundering programme, a further 6 million USD was added.

Authority / court

U.S. Securities and Exchange Commission (SEC)

Area of law

Environment and sustainability · Misleading environmental and sustainability claims

Legal basis

Sections 206(2), 206(4) Investment Advisers Act; Rules 206(4)-7 und 206(4)-8

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

25 Sep 2023

Original amount 19,000,000 USD, converted at the ECB reference rate of 25 Sep 2023.

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

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