Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe and North America: 718 cases from 32 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.

135cases from 28 jurisdictions
€1.05bnTotal of monetary amounts (121 cases with an amount)
€113mLargest single case: The Toronto-Dominion Bank
€615,000Median per case with an amount

Click a bar to drill down one level.

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q3 20232€25.4m
Q4 20236€8.17m
Q1 20248€25.2m
Q2 20243€18.4m
Q3 20244€1.9m
Q4 202410€157.3m
Q1 202513€142.3m
Q2 202510€41.4m
Q3 202520€70.1m
Q4 202519€245.4m
Q1 202612€76.9m
Q2 202614€19.6m
Q3 202614€219.6m

135 cases

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

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

What organisations can take from it

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

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

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

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

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22 Sep 2026 OTC Link LLCOTC Link: 575,000 USD – security policies never completed despite examination findings USACritical infrastructure €501,614

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.

What organisations can take from it

Track supervisory examination findings with a deadline and a responsible person – points that remain open repeatedly become expensive.

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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17 Sep 2026 FleetCor Technologies Inc. (heute Corpay Inc.)FleetCor/Corpay pays 100 million USD over hidden fees on fuel cards USAMisleading advertising and pricing €87.1m

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.

What organisations can take from it

Fees hidden behind links or in account documents are deemed not to have been disclosed – including vis-à-vis business customers.

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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16 Sep 2026 AIFM Capital ABAIFM Capital: 2 million SEK for inadequate selection and oversight of fund managers SwedenOrganisational requirements €177,187

As a so-called fund hotel, the company had its funds managed by other firms, but examined these delegation agreements only insufficiently, did not take the related decisions properly and did not monitor the funds’ returns in relation to risk closely enough. The Swedish financial supervisory authority Finansinspektionen (FI) issued a remark and imposed 2 million SEK; no damage to investors was established.

What organisations can take from it

Outsourcing tasks does not outsource responsibility: document the selection of service providers, the decisions taken and ongoing oversight.

Authority / court
Finansinspektionen (FI)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Schwedisches Fondsrecht – Regeln zur Delegation der Fondsverwaltung und deren Überwachung
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
No established damage to investors; remedial measures already taken during the investigation.
Published
16 Sep 2026

Original amount 2,000,000 SEK, converted at the ECB reference rate of 16 Sep 2026.

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

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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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3 Sep 2026 Banco Bilbao Vizcaya Argentaria, S.A. – Niederlassung Italien (BBVA Italia)Garante: 5.5 million EUR against BBVA Italia over advertising despite objection ItalyMarketing and consent €5.51m

For seven months (October 2025 to May 2026), the bank continued to send a customer advertising via its app, although he had objected several times. The Italian data protection authority (Garante per la protezione dei dati personali) also found deficient systems for implementing objections and inaccurate information about the processing, and imposed 5,508,000 EUR (Provvedimento No. 613).

What organisations can take from it

An objection to advertising must take effect immediately and reliably across all channels – including app messages.

Authority / court
Garante per la protezione dei dati personali
Area of law
Data protection · Marketing and consent
Legal basis
Art. 5 Abs. 1 lit. a, Art. 12, 21, 24 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
11 Sep 2026

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

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

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

What organisations can take from it

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

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

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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17 Aug 2026 Pluxee Česká republika a.s.; Edenred CZ s.r.o.; Up Česká republika s.r.o.Meal voucher cartel: 279 million CZK against Pluxee, Edenred and Up upheld with final effect CzechiaCartels and collusion €11.5m

From 2004 to 2018, the three issuers of paper meal vouchers coordinated with retail chains how many vouchers would be accepted per purchase. The President of the Úřad pro ochranu hospodářské soutěže (Czech Office for the Protection of Competition, ÚOHS) dismissed the appeals against the recalculation of the fines: Pluxee 132.271 million, Edenred 101.94 million and Up 44.941 million CZK, a total of 279.152 million CZK.

What organisations can take from it

Coordinating seemingly technical conditions such as acceptance limits is also a cartel – industry discussions need clear boundaries.

Relevance to training and awareness

Coordination of terms and conditions among competitors

Authority / court
Úřad pro ochranu hospodářské soutěže (ÚOHS)
Area of law
Competition law · Cartels and collusion
Legal basis
Tschechisches Wettbewerbsgesetz, Art. 101 AEUV (R0112/2025)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Published
17 Aug 2026

Original amount 279,152,000 CZK, converted at the ECB reference rate of 17 Aug 2026.

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

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11 Aug 2026 Citibank, N.A., London BranchOFSI imposes 4.7 million GBP on Citibank London over Russia payments United KingdomBreaches of sanctions and embargoes €5.54m

Mainly between February and November 2022, the London branch processed 970 payments totalling around 19.7 million GBP that breached Russia and anti-corruption sanctions. The causes were overloaded alert handling after the wave of designations, delayed escalation and human error; the bank voluntarily disclosed most of the breaches and received a 20% reduction from HM Treasury's Office of Financial Sanctions Implementation (OFSI).

What organisations can take from it

During waves of designations, alert handling needs additional trained capacity – backlogs and wrong decisions in screening are themselves sanctions breaches.

Relevance to training and awareness

Handling sanctions alerts, escalation and freezing

Authority / court
HM Treasury, Office of Financial Sanctions Implementation (OFSI)
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Russia (Sanctions) (EU Exit) Regulations 2019; Global Anti-Corruption Sanctions Regulations 2021; s. 146 Policing and Crime Act 2017
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
Predominantly voluntary disclosure and cooperation (20% reduction); exceptional burden caused by the 2022 sanctions packages taken into account
Published
2 Sep 2026

Original amount 4,732,830.58 GBP, converted at the ECB reference rate of 11 Aug 2026.

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

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5 Aug 2026 Order Express, Inc.NYDFS: $250,000 against money transmitter Order Express over cyber deficiencies USA, NYSecurity measures and risk management €216,375

The licensed money transmitter had no adequate policies for system updates and insufficient risk assessments under New York's cybersecurity regulation, as found by the New York State Department of Financial Services (NYDFS). The company has already remedied the deficiencies.

What organisations can take from it

Even small financial service providers must keep documented patch policies and regular risk assessments.

Authority / court
New York State Department of Financial Services (NYDFS)
Area of law
Information security and cyber · Security measures and risk management
Legal basis
23 NYCRR Part 500 (Cybersecurity Regulation)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Because of its low turnover, the company was exempt from many Part 500 obligations; deficiencies already remedied.
Published
5 Aug 2026

Original amount 250,000 USD, converted at the ECB reference rate of 5 Aug 2026.

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

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

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

What organisations can take from it

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

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

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

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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10 Jul 2026 Brown Capital Management LLCBrown Capital Management: voting rights notifications not submitted on time GermanyDisclosure and reporting obligations €187,500

The Baltimore-based US asset manager had not submitted voting rights notifications to the issuer and BaFin in time; the deadline is four trading days after reaching a notifiable threshold. BaFin imposed a fine of 187,500 EUR; the notice is final.

What organisations can take from it

Anyone investing in German issuers needs automated threshold monitoring with clear responsibility for the four-day deadline.

Relevance to training and awareness

Threshold monitoring and notification deadlines for shareholdings

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
§ 33 Abs. 1 Satz 1 WpHG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
22 Jul 2026

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

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2 Jul 2026 Banca Transilvania S.A.Employee retrieves account statements for a third party – Banca Transilvania pays 5,000 EUR RomaniaData breaches and data security €5,002

At the request of a third party and outside the scope of his duties, a bank employee retrieved account statements of a data subject (name, IBAN, transactions, balances). The Romanian data protection authority (ANSPDCP) found insufficient technical and organisational measures and imposed 26,172 lei (5,000 EUR); the bank has paid the fine. Date = publication of the press release; according to the authority, the investigation was concluded in the previous month.

What organisations can take from it

Access logs and clear rules against ‘favour queries’ are a duty for every bank.

Relevance to training and awareness

Access to customer data for business purposes only; handling requests from third parties

Authority / court
Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 32 Abs. 1, 2 und 4 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
2 Jul 2026

Original amount 26,172 RON, converted at the ECB reference rate of 2 Jul 2026.

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

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30 Jun 2026 Moody's Deutschland GmbHESMA fines Moody's Deutschland 2.1 million EUR EU levelOrganisational requirements €2.15m

The credit rating agency did not submit up-to-date rating information to the European Securities and Markets Authority (ESMA), did not provide complete historical performance data to the central repository and lacked adequate procedures and internal control mechanisms. ESMA found negligent infringements and imposed fines totalling 2,145,000 EUR.

What organisations can take from it

Reporting obligations to the supervisory authority are data quality issues – without functioning internal controls, they become a risk of fines.

Authority / court
Europäische Wertpapier- und Marktaufsichtsbehörde (ESMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Verordnung (EG) Nr. 1060/2009 (CRA-Verordnung), Art. 24, 36a, Anhang III
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Repeat case
yes

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

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30 Jun 2026 „Paysera LT“, UABPaysera: daily fine for missing annual accounts adds up to 362,000 EUR LithuaniaDisclosure and reporting obligations €362,000

Because Paysera did not comply with the order to submit its 2024 annual financial statements by 30 September 2025, the Lietuvos bankas (Bank of Lithuania, financial supervisor) first imposed 20,000 EUR in November 2025 and then a daily fine of 1,000 EUR (rising to 2,000 and 3,000 EUR respectively). As the infringement was only remedied after 6 May 2026, the daily fine added up to 362,000 EUR. Source: archived copy of the press release.

What organisations can take from it

Running daily fines make every delay expensive – supervisory orders need top-management priority.

Authority / court
Lietuvos bankas (Litauische Zentralbank, Finanzaufsicht)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Aufsichtsrechtliche Anordnung und Berichtspflichten nach litauischem E-Geld-Recht
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Published
30 Jun 2026

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

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26 Jun 2026 Banque Degroof Petercam SABanque Degroof Petercam: 1 million EUR settlement over hidden costs in employee stock options BelgiumOrganisational requirements €1m

In stock option plans for employees of client companies (2018–2023), the bank did not fully inform the beneficiaries about costs, had initially not recorded the conflicts of interest in this business and assessed clients’ knowledge only with a yes/no question. The Autorité des services et marchés financiers (Belgian Financial Services and Markets Authority, FSMA) accepted a settlement of 1 million EUR with publication by name and commitments on cost information.

What organisations can take from it

Full cost transparency and a dedicated conflicts register also apply to ancillary business such as employee stock option plans.

Authority / court
Autorité des services et marchés financiers (FSMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Loi du 2 août 2002; Wohlverhaltensregeln (Loyalität, Kostentransparenz, bestmögliche Ausführung, Interessenkonflikte, Kundenkenntnis)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
Remediation of all deficiencies (appropriateness test, conflicts policy, cost disclosure, waiver of CVA/KVA discounts).
Published
26 Jun 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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22 Jun 2026 Inkasso-Team AGFederal Administrative Court upholds FDPIC: Inkasso-Team was not allowed to publish debtor data SwitzerlandData subject rights and transparency Order

The debt collection company posted personal data of alleged debtors on the internet, some of it particularly sensitive, in order to obtain information on their whereabouts and to warn third parties. The Swiss Federal Administrative Court (Bundesverwaltungsgericht, A-3891/2025) upheld the ruling of the Federal Data Protection and Information Commissioner (EDÖB) of 28 April 2025, according to which this constitutes an unjustified violation of privacy.

What organisations can take from it

Publicly naming and shaming debtors cannot be justified under data protection law – debt collection must use less intrusive means.

Authority / court
Bundesverwaltungsgericht (A-3891/2025) auf Verfügung des EDÖB vom 28.04.2025
Area of law
Data protection · Data subject rights and transparency
Legal basis
DSG Art. 6, Art. 19, Art. 31
Action
Order
Status of proceedings
final
Sector
Financial services and insurance
Published
20 Aug 2026

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
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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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25 May 2026 Robomarkets LtdCyprus: Robomarkets pays 100,000 EUR under settlement over CFD sales to retail clients CyprusOrganisational requirements €100,000

For the period June 2023 to June 2024, the Cyprus Securities and Exchange Commission (CySEC) examined the investment firm’s organisational requirements, client information, appropriateness assessment and compliance with the restrictions on marketing CFDs to retail investors. The proceedings were concluded with a settlement of 100,000 EUR, which the company has already paid.

What organisations can take from it

When selling CFDs to retail clients, the appropriateness assessment and product intervention rules are central points of supervisory scrutiny.

Relevance to training and awareness

Appropriateness assessment when selling complex products

Authority / court
Cyprus Securities and Exchange Commission (CySEC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 22(1), 25(1), 26(3) Gesetz über Wertpapierdienstleistungen 2017; Art. 42 VO (EU) 600/2014; CySEC-Richtlinie DI87-09; Art. 37(4) CySEC-Gesetz
Action
Other
Status of proceedings
final
Sector
Financial services and insurance
Published
24 Aug 2026
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13 May 2026 Oma Säästöpankki OyjOma Säästöpankki: 400,000 EUR over late and incomplete insider lists FinlandMarket abuse and insider dealing €400,000

The bank failed to draw up insider lists in good time for two pieces of inside information (termination of the core banking project with Cognizant in 2021, merger talks with Liedon Säästöpankki in 2022), did not update them and omitted mandatory information. The Finanssivalvonta (Finnish Financial Supervisory Authority, FIN-FSA) imposed a total fine of 400,000 EUR; the decision was not appealed and is final.

What organisations can take from it

Insider lists must be created from the moment inside information exists – a fixed process with designated responsible persons prevents gaps.

Relevance to training and awareness

Insider lists and handling of inside information

Authority / court
Finanssivalvonta (FIN-FSA)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Verordnung (EU) Nr. 596/2014 (MAR) Art. 18 Abs. 1, 3 und 4; Durchführungsverordnung (EU) 2016/347
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Measures to prevent recurrence and partial admission/cooperation had a mitigating effect.
Published
15 May 2026

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8 May 2026 Permanent TSB plcDPC: 277,500 EUR against Permanent TSB after account takeovers via call centre calls IrelandData breaches and data security €277,500

Fraudsters in possession of customer data posed as customers at the bank's ‘Open24’ call centre, had account details changed and obtained further information because security protocols were not followed; those affected had to close accounts, and some suffered losses. Ireland's Data Protection Commission (DPC) imposed 250,000 EUR for inadequate security and 27,500 EUR for late breach notification (decision served in the week before the press release).

What organisations can take from it

Call centre staff must adhere to identity checks without exception – callers with ‘matching’ data are not automatically authorised.

Relevance to training and awareness

Identity verification by telephone (vishing)

Authority / court
Data Protection Commission (DPC)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 5 Abs. 1 lit. f, Art. 32 Abs. 1, Art. 33 Abs. 1 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
8 May 2026

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

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5 May 2026 P&V Assurances SCP&V Assurances: 150,000 EUR – distribution via a deregistered insurance intermediary BelgiumOrganisational requirements €150,000

One of the insurer’s intermediaries was removed from the FSMA register in December 2023; owing to a human data entry error in the monitoring tool, P&V only noticed this after more than a month and concluded 34 contracts through him during that time. The Autorité des services et marchés financiers (Belgian Financial Services and Markets Authority, FSMA) accepted a settlement of 150,000 EUR; there had already been a settlement for the same amount in 2020.

What organisations can take from it

Automated register checks are only as good as the underlying data maintenance – critical entries require a four-eyes principle.

Relevance to training and awareness

Care in master data maintenance / register reconciliation

Authority / court
Autorité des services et marchés financiers (FSMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Loi du 4 avril 2014 relative aux assurances, Art. 259
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
IT adjustments to prevent recurrence.
Published
5 May 2026

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

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4 May 2026 Malta: insurer reprimanded again and fined – marketing calls despite objection MaltaMarketing and consent €1,000

Although the Information and Data Protection Commissioner (IDPC) had already ruled in favour of a complainant, an insurance company (name redacted) again had him called for marketing purposes via a third-party company; his number remained on call lists. The IDPC criticised the lack of safeguards and inadequate contracts with processors, ordered remedial action within 20 days and imposed two fines totalling 1,000 EUR.

What organisations can take from it

An objection to marketing must also reach all call centres engaged – otherwise the next complaint follows.

Relevance to training and awareness

Passing marketing objections on to service providers (suppression lists)

Authority / court
Information and Data Protection Commissioner (IDPC)
Area of law
Data protection · Marketing and consent
Legal basis
Art. 5 Abs. 2, Art. 21 Abs. 2, Art. 24 Abs. 1, Art. 28 Abs. 3 i. V. m. Art. 58 Abs. 2 lit. b, d, i DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Sources

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

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29 Apr 2026 Delta Dental Insurance Company und Delta Dental of New York, Inc.NYDFS: $2.25 million against Delta Dental after MOVEit attack and late notification USA, NYSecurity measures and risk management €1.92m

In 2023, attackers exploited a zero-day vulnerability in MOVEit Transfer to steal files containing social security, driving licence, account and health data. The New York State Department of Financial Services (NYDFS) criticised inadequate retention settings, policies and controls as well as the late notification of the cybersecurity incidents to the supervisory authority.

What organisations can take from it

Keep data in transfer tools only for as long as necessary – and report security incidents to the supervisory authority on time.

Authority / court
New York State Department of Financial Services (NYDFS)
Area of law
Information security and cyber · Security measures and risk management
Legal basis
23 NYCRR Part 500 (Cybersecurity Regulation)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
negligent
Published
30 Apr 2026

Original amount 2,250,000 USD, converted at the ECB reference rate of 29 Apr 2026.

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

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15 Apr 2026 Liquidnet Canada Inc.Liquidnet Canada: confidential order data passed on to unauthorised persons Canada, ONOrganisational requirements €369,572

The operator of alternative trading systems passed on confidential order and trading information from its fixed income and equity platforms to unauthorised employees, lacked adequate safeguards and was initially not forthcoming with the regulator. Sanctions: administrative penalty of 600,000 CAD, 75,000 CAD in costs, a reprimand and an external review.

What organisations can take from it

Technically restrict access rights to confidential client data and review them regularly – and make complete reports to the regulator.

Relevance to training and awareness

Need-to-know principle and protection of confidential trading data

Authority / court
Capital Markets Tribunal (Ontario) auf Antrag der Ontario Securities Commission
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
National Instrument 21-101, s. 5.10(1)-(3); Securities Act (Ontario) ss. 127(1), 127.1
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Cooperation, self-report, no prior record

Original amount 600,000 CAD, converted at the ECB reference rate of 15 Apr 2026.

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Recognising and reporting grounds for suspicion in crypto exchange

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

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

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

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27 Mar 2026 Dinosaur Merchant Bank LimitedDinosaur Merchant Bank: 338,000 GBP – CFD trading without market abuse surveillance United KingdomOrganisational requirements €389,760

After a new order management system was introduced in June 2024, CFD transactions with an underlying value of around 3.05 billion USD were not captured by automated trade surveillance. The bank identified the error in October 2024 but only remedied it in May 2025; the Financial Conduct Authority (FCA) imposed 338,000 GBP after a 30% cooperation discount.

What organisations can take from it

With every system migration, check whether surveillance systems actually capture the new data flows.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 16 Abs. 2 UK MAR; SYSC 6.1.1R; FCA Principle 3
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Full cooperation (30% discount); CFD business discontinued in May 2025.

Original amount 338,000 GBP, 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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25 Mar 2026 Familiam Asset Management OyFamiliam Asset Management: 70,000 EUR for 2,867 unreported securities transactions FinlandDisclosure and reporting obligations €70,000

Between September 2021 and August 2023, the asset manager failed to report a total of 2,867 transactions to the supervisory authority on time and in 2024 also submitted quarterly reports (FINREP) late. The Finanssivalvonta (Finnish Financial Supervisory Authority, FIN-FSA) imposed a total fine of 70,000 EUR; the admission had a mitigating effect.

What organisations can take from it

Reporting obligations require deadline monitoring with a deputy arrangement – especially in small firms without their own reporting department.

Relevance to training and awareness

Regulatory reporting

Authority / court
Finanssivalvonta (FIN-FSA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
MiFIR (VO (EU) 600/2014) Art. 26 Abs. 1; IFR (VO (EU) 2019/2033) Art. 54 Abs. 1; FIN-FSA-Vorschriften 20/2013 (FINREP)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Admission of the failures / cooperation.
Published
25 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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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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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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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 REGIS-TR S.A.Trade repository REGIS-TR: deficiencies in organisation and data protection – 1.37 million EUR EU levelOrganisational requirements €1.37m

The Luxembourg trade repository lacked adequate compliance procedures and an appropriate organisational structure, failed to identify operational risks and did not adequately protect the confidentiality and integrity of the reported data. ESMA imposed fines totalling 1,374,000 EUR for negligent infringements under EMIR and SFTR; the case is under appeal.

What organisations can take from it

Market infrastructures must manage operational risks and data access as strictly as banks manage their credit risks.

Authority / court
Europäische Wertpapier- und Marktaufsichtsbehörde (ESMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Verordnung (EU) Nr. 648/2012 (EMIR), Art. 65, 73, Anhang I; Verordnung (EU) 2015/2365 (SFTR), Art. 9
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Culpability
negligent
Repeat case
yes

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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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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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
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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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18 Dec 2025 Croatia: 1.5 million EUR against bank whose app recorded all apps installed by customers CroatiaData subject rights and transparency €1.5m

The mobile banking app of a bank (name not published) scanned the list of all installed applications on the Android and Huawei devices of 433,922 customers and stored it centrally – without a legal basis, without transparent information and without a data-minimising design. The Agencija za zaštitu osobnih podataka (Croatian Personal Data Protection Agency, AZOP) imposed 1.5 million EUR; the decision is not final (date = publication).

What organisations can take from it

Fraud prevention does not justify capturing device data in full – a blocklist of known malicious apps would have been the less intrusive means.

Authority / court
Agencija za zaštitu osobnih podataka (AZOP)
Area of law
Data protection · Data subject rights and transparency
Legal basis
Art. 5 Abs. 1 lit. a und c, Art. 6 Abs. 1, Art. 12, 13, 25 Abs. 2 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
18 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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11 Dec 2025 „ЗП Либра“ ООДZP Libra: 44,205 leva for poaching customers using competitor’s trade secrets BulgariaCompetition law €22,602

With the help of an employee of its competitor I&G Insurance Brokers who later moved to ZP Libra, the broker unfairly concluded a brokerage agreement to the detriment of the competitor and used the competitor’s trade secrets to poach customers. The Комисия за защита на конкуренцията (Bulgarian Commission for the Protection of Competition, KZK) imposed 29,470 leva (1% of 2024 turnover, Art. 36(1) ZZK – Bulgarian Protection of Competition Act) and 14,735 leva (0.5%, Art. 37(1) ZZK); fines totalling 1,000 leva were also imposed on the employee.

What organisations can take from it

When hiring employees from competitors, make sure they do not bring customer lists or secrets with them – otherwise both the company and the individual are liable.

Relevance to training and awareness

Taking customer data and trade secrets when changing employer

Authority / court
Комисия за защита на конкуренцията (КЗК, Bulgarische Wettbewerbskommission)
Area of law
Competition law
Legal basis
Art. 36 Abs. 1, Art. 37 Abs. 1 ZZK
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Fines on the employee involved (1,000 leva in total)
Published
16 Dec 2025

Original amount 44,205 BGN, converted at the ECB reference rate of 11 Dec 2025.

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

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10 Dec 2025 Invest in OÜLender Invest in OÜ pays 16,000 EUR for failing to submit annual accounts EstoniaDisclosure and reporting obligations €16,000

The lender did not submit its 2024 annual report, together with the audit report, the resolution on the appropriation of profits and the minutes of the shareholders’ meeting, to the financial supervisory authority on time. In misdemeanour proceedings, the Finantsinspektsioon (Estonian Financial Supervision Authority) imposed a fine of 16,000 EUR; the maximum is 1 million EUR or 10% of annual turnover. Date = publication.

What organisations can take from it

Even small supervised lenders need a reliable deadline calendar for mandatory supervisory reports.

Authority / court
Finantsinspektsioon (Estnische Finanzaufsicht)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
§ 56 Abs. 3, § 96 Abs. 2 KAVS (Gesetz über Kreditgeber und -vermittler)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
10 Dec 2025

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2 Dec 2025 IPI Partners, LLCPrivate equity firm IPI held oligarch's funds for four years after designation USABreaches of sanctions and embargoes €9.89m

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.

What organisations can take from it

Screen investors through to the beneficial owner and re-check them when new designations occur – nested structures do not protect against liability.

Relevance to training and awareness

Checking beneficial owners of investors and fund structures

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.

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27 Nov 2025 American Express Carte FranceAmerican Express Carte France: 1.5 million EUR – marketing cookies despite ‘Reject all’ FranceCookies and tracking €1.5m

When the website was accessed, eight non-exempt cookies were placed without any user action; after ‘Reject all’, three marketing cookies were nevertheless placed when switching to an affiliated domain, and after consent was withdrawn, cookies continued to be read. The Commission nationale de l’informatique et des libertés (French data protection authority, CNIL) imposed 1.5 million EUR for this and, in view of the rectification during the proceedings, refrained from issuing an order; it found an infringement of data minimisation in the recording of customer calls but did not sanction it.

What organisations can take from it

Cookie settings must apply across all domains of a service – including when users move to affiliated sites.

Authority / court
Commission nationale de l'informatique et des libertés (CNIL), formation restreinte
Area of law
Data protection · Cookies and tracking
Legal basis
Art. 82 Loi Informatique et Libertés (Geldbuße); Verstoß gegen Art. 5 Abs. 1 lit. c DSGVO (Gesprächsaufzeichnungen) festgestellt, aber nicht sanktioniert
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
Corrections during the proceedings, cooperation.

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

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11 Nov 2025 Avida Finans ABAvida Finans: 20 million SEK for loans to consumers unable to repay SwedenConsumer protection and online retail €1.82m

The Swedish financial supervisory authority Finansinspektionen (FI) examined consumer loans granted by the lender over four weeks in summer 2024 and found at least around 30 cases in which consumers without the ability to repay received loans. FI issued a remark and imposed 20 million SEK.

What organisations can take from it

Carry out credit checks consistently even under sales pressure and verify them internally through sample checks.

Relevance to training and awareness

Creditworthiness assessment in sales

Authority / court
Finansinspektionen (FI)
Area of law
Consumer protection and online retail
Legal basis
Konsumentkreditlagen (2010:1846), Kreditprüfung
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
11 Nov 2025

Original amount 20,000,000 SEK, converted at the ECB reference rate of 11 Nov 2025.

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

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

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

What organisations can take from it

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

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

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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23 Oct 2025 Aktia Pankki OyjAktia: 865,000 EUR – other people’s data visible in OmaKanta and OmaKela via bank login FinlandData breaches and data security €865,000

Following a technical change to the bank’s strong electronic identification service, a disruption lasting around one hour occurred in January 2023 during which customers logging in with Aktia credentials to services such as OmaKanta, OmaKela, unemployment funds, insurers and healthcare providers saw data of other persons; around 350 people were affected. The sanctions board of the Tietosuojavaltuutetun toimisto (Office of the Data Protection Ombudsman) criticised the deficient planning, implementation and testing of the change and imposed 865,000 EUR in addition to a reprimand.

What organisations can take from it

Changes to identification services have effects far beyond one’s own organisation – testing and release processes must reflect this.

Authority / court
Tietosuojavaltuutetun toimisto – seuraamuskollegio (Datenschutzbeauftragter, Sanktionsgremium)
Area of law
Data protection · Data breaches and data security
Legal basis
DSGVO Art. 5 Abs. 1 lit. f, Art. 25, Art. 32
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
28 Oct 2025

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

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21 Oct 2025 Taxshelter.be SATaxshelter.be: 75,000 EUR for missing prospectus supplement on guarantee risks BelgiumDisclosure and reporting obligations €75,000

After the tax authority had refused the tax shelter certificates for a financed show and the insurer left cover open, the provider failed to inform investors of this material risk in good time by means of a prospectus supplement. The Autorité des services et marchés financiers (Belgian Financial Services and Markets Authority, FSMA) accepted a settlement of 75,000 EUR with publication by name.

What organisations can take from it

New material risks for investors trigger an immediate obligation to publish a supplement – not only in the next annual prospectus.

Authority / court
Autorité des services et marchés financiers (FSMA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Verordnung (EU) 2017/1129 Art. 23; Loi du 11 juillet 2018 (Loi Prospectus)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
21 Oct 2025

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

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

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

What organisations can take from it

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

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

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

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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14 Oct 2025 Farmers Insurance ExchangeNYDFS: $2.775 million against Farmers over unprotected online quoting tools USA, NYSecurity measures and risk management €2.4m

Attackers harvested driving licence numbers and dates of birth via inadequately secured online quoting tools and agent portals. According to the New York State Department of Financial Services (NYDFS), Farmers infringed the cybersecurity regulation and did not report the incident in time; the penalty is part of a package totalling $19 million against eight motor insurers.

What organisations can take from it

Automatically pre-filled forms containing customer data are a point of entry – scrutinise public-facing applications for the data they disclose.

Authority / court
New York State Department of Financial Services (NYDFS)
Area of law
Information security and cyber · Security measures and risk management
Legal basis
23 NYCRR Part 500 (Cybersecurity Regulation)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
negligent
Published
14 Oct 2025

Original amount 2,775,000 USD, converted at the ECB reference rate of 14 Oct 2025.

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

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14 Oct 2025 Infinity Insurance CompanyInfinity Insurance: 2.25 million USD – data leak via quoting tool reported too late USA, NYIncident reporting obligations €1.95m

Attackers extracted driver’s licence numbers in plain text via the motor insurer’s instant quote applications. Infinity discovered the anomalies on 9 February 2021 but only reported the cybersecurity event to the New York State Department of Financial Services (NYDFS) on 14 April 2021; the supervisor also criticised the lack of MFA and insecure development practices.

What organisations can take from it

Misuse of publicly accessible customer applications is also a reportable incident – warnings from the supervisor should trigger an immediate reporting assessment.

Authority / court
New York State Department of Financial Services (NYDFS)
Area of law
Information security and cyber · Incident reporting obligations
Legal basis
23 NYCRR § 500.17(a), § 500.12(a) u. a.
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
negligent

Original amount 2,250,000 USD, converted at the ECB reference rate of 14 Oct 2025.

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

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14 Oct 2025 AS Inbank FinanceOrder against Inbank Finance over deficiencies in creditworthiness assessment EstoniaConsumer protection and online retail Order

During an inspection, the Finantsinspektsioon (Estonian Financial Supervision Authority) found that Inbank Finance’s internal rules on assessing the creditworthiness of consumers did not fully comply with the law and that the assessment itself showed deficiencies. It issued an order requiring the company to remedy the deficiencies by mid-December. Date = publication.

What organisations can take from it

Creditworthiness assessments must be documented, rule-based and actually applied in day-to-day business.

Relevance to training and awareness

Responsible lending in sales

Authority / court
Finantsinspektsioon (Estnische Finanzaufsicht)
Area of law
Consumer protection and online retail
Legal basis
Gesetz über Kreditgeber und -vermittler (KAVS), verantwortungsvolle Kreditvergabe
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Published
14 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 Wonderinterest Trading LtdCyprus: 100,000 EUR against Wonderinterest Trading over misleading client information CyprusOrganisational requirements €100,000

For 2022 to 2024, the Cyprus Securities and Exchange Commission (CySEC) found that the investment firm had no adequate compliance procedures, did not define target markets for its financial instruments, did not act in the best interests of clients and did not inform clients in a fair, clear and not misleading manner. It imposed fines of 50,000, 30,000 and 20,000 EUR; a judicial review of the decision has been recorded.

What organisations can take from it

Advertising statements by financial service providers must present risks in a balanced way – marketing belongs in the compliance approval process.

Relevance to training and awareness

Fair and not misleading marketing communications

Authority / court
Cyprus Securities and Exchange Commission (CySEC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Sec. 17(2), 17(3)(c), 22(1), 25(1), 25(3)(a) Gesetz über Wertpapierdienstleistungen 2017; Art. 22, 44 Delegierte VO (EU) 2017/565
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
17 Dec 2025

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

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13 Oct 2025 Finamore S.A.Finamore: licence of insurance broker withdrawn over serious deficiencies LuxembourgOrganisational requirements Other

The Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) withdrew the broking firm’s licence (effective from 1 December 2025), among other things for using unregistered intermediaries, lacking internal expertise, insufficiently protected confidential data, economically unexplained payment flows with affiliated companies, incomplete or false information provided to the supervisory authority and deficient customer information.

What organisations can take from it

False information to the supervisory authority and unregistered distribution partners can cost the business its existence – not just a fine.

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Loi modifiée du 7 décembre 2015 sur le secteur des assurances, Art. 303 Abs. 3 lit. c
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
29 May 2026

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

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22 Sep 2025 Nova Ljubljanska banka d. d.NLB: reprimand because PSD2 interface exposed 57 account numbers SloveniaSecurity measures and risk management Reprimand or warning

After an update of the PSD2 interface for third-party providers in July 2023, the confidentiality of 57 IBAN accounts of bank customers was not ensured. The banking supervisor, Banka Slovenije (Bank of Slovenia), issued a reprimand to the bank and to the responsible IT development director for breaching the obligation to protect confidential data (final).

What organisations can take from it

Every change to customer interfaces requires testing for data leakage before go-live – responsibility also lies with the manager in charge.

Relevance to training and awareness

Security testing for software releases of interfaces

Authority / court
Banka Slovenije
Area of law
Information security and cyber · Security measures and risk management
Legal basis
Art. 146, Art. 396 Abs. 1 Nr. 18 ZBan-3 (slowenisches Bankengesetz)
Action
Reprimand or warning
Status of proceedings
final
Sector
Financial services and insurance
Liability of senior managers
Reprimand also issued to the responsible Director of IT Development (Dejan Pust).

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

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16 Sep 2025 Go West Invest SAGo West Invest: 10,000 EUR for outdated information note in tax shelter offering BelgiumDisclosure and reporting obligations €10,000

From June 2021 to October 2024, the company, which raises tax shelter funds through public offerings, kept a public offering on its website with an information note from 2020 without publishing an updated note and filing it with the Autorité des services et marchés financiers (Belgian Financial Services and Markets Authority, FSMA); several dozen investors with an investment volume of under 5 million EUR were affected. The FSMA accepted a settlement of 10,000 EUR.

What organisations can take from it

Investor information has an expiry date – a deadline calendar for mandatory documents prevents infringements.

Authority / court
Autorité des services et marchés financiers (FSMA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Loi du 11 juillet 2018 (Loi Prospectus), Art. 10, 11
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
16 Sep 2025

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

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8 Sep 2025 S-Pankki OyjS-Pankki: 1.8 million EUR over security flaw in bank identification service FinlandData breaches and data security €1.8m

After a new login function was introduced in the S-mobiili app in April 2022, a vulnerability in the identification service made it possible until August 2022 to access online banking and services requiring strong authentication using other customers’ credentials; misuse caused financial losses. The bank had introduced the function without sufficient risk analysis and testing; the sanctions board of the Tietosuojavaltuutetun toimisto (Office of the Data Protection Ombudsman) imposed 1.8 million EUR in addition to a reprimand, with a previous reprimand acting as an aggravating factor.

What organisations can take from it

Before launch, new functions in authentication services require a risk analysis of all user paths and targeted security testing.

Authority / court
Tietosuojavaltuutetun toimisto – seuraamuskollegio (Datenschutzbeauftragter, Sanktionsgremium)
Area of law
Data protection · Data breaches and data security
Legal basis
DSGVO Art. 5 Abs. 1 lit. f, Art. 25 Abs. 1, Art. 32 Abs. 1 und 2
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
The fine imposed by the financial supervisory authority (7.67 million EUR) for the same facts was taken into account (fine around one third of the amount that would otherwise have been imposed); according to the bank, it compensated customers for direct losses.
Published
10 Sep 2025

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

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5 Sep 2025 „Paysera LT“, UABPaysera took over e-money institution Contis without approval – 400,000 EUR LithuaniaOrganisational requirements €400,000

Paysera acquired 100% of the shares in UAB ‘Finansinės paslaugos „Contis“’ before the assessment period had expired and without a non-objection from the supervisory authority; in April 2025, the Lietuvos bankas (Bank of Lithuania, financial supervisor) objected to the acquisition owing to a lack of documents on reputation, financial soundness and money laundering risks. In addition, the annual financial statements and other reports were not approved and submitted on time. Fine of 400,000 EUR and obligation to remedy by 30 September 2025. Source: archived copy of the press release.

What organisations can take from it

Complete acquisitions of holdings in supervised institutions only after approval – otherwise voting rights are suspended and fines loom.

Authority / court
Lietuvos bankas (Litauische Zentralbank, Finanzaufsicht)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Elektroninių pinigų ir elektroninių pinigų įstaigų įstatymas (Inhaberkontrolle, Berichtspflichten)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
5 Sep 2025

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

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1 Sep 2025 Blacktower Financial Management (Cyprus) LtdCyprus: Blacktower Financial Management pays 70,000 EUR over conflicts of interest CyprusOrganisational requirements €70,000

For the period November 2020 to May 2025, the Cyprus Securities and Exchange Commission (CySEC) investigated the investment firm’s handling of conflicts of interest and its general conduct of business and information obligations towards clients. The proceedings ended with a settlement of 70,000 EUR, which the company has paid.

What organisations can take from it

Conflicts of interest must be identified, documented and managed vis-à-vis clients – adviser training is the basis for this.

Relevance to training and awareness

Recognising conflicts of interest in investment advice

Authority / court
Cyprus Securities and Exchange Commission (CySEC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 24(1), 25(1) Gesetz über Wertpapierdienstleistungen 2017; Art. 37(4) CySEC-Gesetz
Action
Other
Status of proceedings
final
Sector
Financial services and insurance
Published
17 Nov 2025

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money laundering and PEP clients

Authority / court
Bundesanwaltschaft
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 102 Abs. 2 StGB i. V. m. Art. 305bis Abs. 1 und 2 StGB
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Time elapsed since the offence, organisational corrective measures after the affair became known; no compensation claim because of the payment of 16 million CHF to Petrobras.
Liability of senior managers
A former asset manager was separately given a suspended prison sentence of six months for aggravated money laundering (offences committed at another Swiss bank).
Published
22 Aug 2025

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

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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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14 Aug 2025 Healthplex, Inc.Healthplex: 2 million USD – phishing incident not reported to supervisor for months USA, NYIncident reporting obligations €1.71m

An employee of the dental insurance service provider disclosed his login credentials via a phishing e-mail; the mailbox containing over 100,000 e-mails with health and social security data was accessible. Healthplex had known about the incident since November 2021 but only reported it to the New York State Department of Financial Services (NYDFS) in April 2022 instead of within 72 hours; in addition, there was no MFA for web access and no data retention and deletion policy.

What organisations can take from it

Security incidents require a fixed reporting process with deadline control – the 72-hour clock starts when the incident is identified, not when forensics is completed.

Relevance to training and awareness

Recognising phishing; reporting channels for security incidents

Authority / court
New York State Department of Financial Services (NYDFS)
Area of law
Information security and cyber · Incident reporting obligations
Legal basis
23 NYCRR § 500.17(a), § 500.12(b), § 500.13, § 500.17(b)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
negligent

Original amount 2,000,000 USD, converted at the ECB reference rate of 14 Aug 2025.

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12 Aug 2025 Asociația Casa de Ajutor Reciproc „FLEXICREDIT”Credit association Flexicredit grants 17 loans on forged documents – 3,000 EUR RomaniaData breaches and data security €2,990

A school employee gained access to her school’s official e-mail account and sent forged documents on the basis of which the credit association concluded 17 loans in 2023/2024 without the knowledge of the data subjects. The Romanian data protection authority (ANSPDCP) criticised the insufficient identity verification for remote applications and imposed 15,141.6 lei (3,000 EUR). Date = publication of the press release; according to the authority, the investigation was concluded in June 2025.

What organisations can take from it

Remote contracting requires robust identity verification – an e-mail from an ‘official’ address is no proof.

Relevance to training and awareness

Identity verification and fraud detection in remote applications

Authority / court
Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 32 Abs. 2 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
12 Aug 2025

Original amount 15,141.6 RON, converted at the ECB reference rate of 12 Aug 2025.

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

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

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

What organisations can take from it

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

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

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

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

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7 Aug 2025 Liberty Mutual Insurance CompanyLiberty Mutual: declination against 4.7 million USD after bribery of Indian state bank employees USABribery of public officials €4.04m

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.

What organisations can take from it

Employees of state-owned banks are public officials – sales commissions paid to them are bribes, even if they are booked as marketing.

Relevance to training and awareness

Distribution partnerships with state-owned banks, payments disguised as marketing

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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23 Jul 2025 ESTO ASData protection authority requires ESTO AS to stop creating accounts for non-customers EstoniaData subject rights and transparency Order

The instalment payment provider created customer profiles without a contract for persons who signed in via retailer checkouts, refused former customers the closure of their accounts and continued to send them transactional e-mails with advertising content. The Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate, AKI) ordered transparent information, valid consent, erasure options under Art. 17 GDPR and the separation of transactional and advertising e-mails; a penalty payment of 5,000 EUR is threatened for each item not fulfilled.

What organisations can take from it

Customer accounts must not be created for non-customers ‘on the side’ – and erasure must work once the contract has ended.

Authority / court
Andmekaitse Inspektsioon (AKI)
Area of law
Data protection · Data subject rights and transparency
Legal basis
§ 56 Abs. 1, § 58 Abs. 1 IKS; Art. 58 Abs. 2 lit. d, Art. 4 Nr. 11, 5, 6, 7, 12–14, 17 DSGVO
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance

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

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23 Jul 2025 Condor Courtiers & Conseillers S.à r.l.Condor Courtiers & Conseillers: licence withdrawn for using unlicensed introducers LuxembourgOrganisational requirements Other

Following an on-site inspection in 2024, the Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) withdrew the broker’s licence (effective 15 September 2025): there was no effective management by approved managers, unlicensed ‘introducers’ were de facto selling insurance, and the broker’s licence, together with its sub-intermediary network, was improperly made available to third parties.

What organisations can take from it

A distribution licence is not transferable – anyone who ‘rents it out’ to third parties or lets introducers sell risks having it withdrawn.

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Loi modifiée du 7 décembre 2015 sur le secteur des assurances, Art. 273, 274, 283, 286, 303
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
16 Sep 2025

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

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10 Jul 2025 Poste Vita S.p.A.Poste Vita: 80,000 EUR – data breach notified only four months after customer’s alert ItalyIncident reporting obligations €80,000

A fraudster impersonated a customer by e-mail and, between 2021 and 2023, obtained information and documents on three policies from the life insurer’s case handlers without his identity being verified. Although the customer alerted the company to the false e-mail address in September 2024, Poste Vita only notified the breach to the supervisory authority in January 2025.

What organisations can take from it

Customer alerts about possible data leaks must go into the incident assessment immediately – not only after internal checks are completed.

Relevance to training and awareness

Identity verification for customer requests by e-mail (social engineering)

Authority / court
Garante per la protezione dei dati personali
Area of law
Information security and cyber · Incident reporting obligations
Legal basis
Art. 5 Abs. 1 lit. a und f, Art. 33 Abs. 1 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Mitigating circumstances
Immediate blocking of further communication, internal investigation, criminal complaint and stricter identity verification.

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

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

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

What organisations can take from it

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

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

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

Sources

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8 Jul 2025 Barents Reinsurance S.A.Barents Reinsurance: maximum fine of 250,000 EUR over governance deficiencies LuxembourgOrganisational requirements €250,000

The reinsurer breached the principle of specialisation in reinsurance business, its approved manager was not effectively present on site and had insufficient powers, the governance system including oversight of outsourced functions was inadequate, and orders from a 2019 inspection had not been implemented or only partially. The Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) imposed the statutory maximum of 250,000 EUR; the company cooperated.

What organisations can take from it

On-site substance is a supervisory requirement: management, powers and oversight of outsourced functions must genuinely be located in the home country.

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Loi modifiée du 7 décembre 2015 sur le secteur des assurances, Art. 49, 71, 81, 274, 303
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation with the CAA during and after the inspection.
Published
8 Aug 2025

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Plausibility checks in customer onboarding

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

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

Sources

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2 Jul 2025 Hrvatski ured za osiguranje (HUO)AZOP: 101,000 EUR against Croatian Insurance Bureau after leak of vehicle owner data CroatiaData breaches and data security €101,000

Following an anonymous tip-off about a USB stick containing data on more than one million vehicle owners (name, OIB, address, registration number, insurance data), the Croatian data protection authority (Agencija za zaštitu osobnih podataka, AZOP) found that the data originated from the database of the Insurance Bureau, which had not laid down appropriate protective measures or deletion periods. Because of its public tasks, the fine was capped at 101,000 EUR (date of publication; exact date of the decision not stated).

What organisations can take from it

Large registers need access controls, export logging and deletion periods so that bulk data does not end up unnoticed on USB sticks.

Relevance to training and awareness

Access control and deletion periods for register data

Authority / court
Agencija za zaštitu osobnih podataka (AZOP)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 5 Abs. 1 lit. e, Art. 32 Abs. 2 und 4 DSGVO; Art. 44 kroatisches DSGVO-Durchführungsgesetz
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cap due to public tasks (Art. 44 of the Implementing Act).
Published
2 Jul 2025

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Identification for cash deposits by non-customers

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

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

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

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

What organisations can take from it

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Recognising cash as a risk factor

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

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

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

Between 2010 and 2013, an asset manager at the bank validated 54 transfers through which bribes of around 4.1 million USD connected with SBM Offshore's charter contracts with Petrobras were concealed. The bank had not classified high-risk accounts as such and had inadequately monitored transfers; the Office of the Attorney General of Switzerland (Bundesanwaltschaft) imposed a fine of 2 million CHF, and the former employee received a suspended prison sentence.

What organisations can take from it

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

Relevance to training and awareness

High-risk clients and transaction monitoring

Authority / court
Bundesanwaltschaft
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 102 Abs. 2 StGB i. V. m. Art. 305bis und Art. 322septies StGB
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Time elapsed since the offence, very good cooperation, organisational corrective measures after the Petrobras affair became known.
Liability of senior managers
Former asset manager: suspended prison sentence of six months (probation period of two years).
Published
17 Jun 2025

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

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11 Jun 2025 Svea Finance AS200,000 EUR fine against Svea Finance over deficient creditworthiness assessment EstoniaConsumer protection and online retail €200,000

Between December 2023 and February 2024, Svea Finance’s internal rules on consumer lending did not comply with the law (50,000 EUR), and the company concluded credit agreements without assessing all prescribed creditworthiness components (150,000 EUR). Fines totalling 200,000 EUR for two misdemeanours. Date = publication.

What organisations can take from it

Creditworthiness assessments must cover all factors prescribed by law – gaps in internal policies are sanctioned separately.

Relevance to training and awareness

Responsible lending

Authority / court
Finantsinspektsioon (Estnische Finanzaufsicht)
Area of law
Consumer protection and online retail
Legal basis
§ 98 Abs. 2 und § 99 Abs. 2 KAVS
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
11 Jun 2025

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

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5 Jun 2025 CaixaBank, S.A.AEPD: 200,000 EUR against CaixaBank over continued storage of a non-customer's data SpainMarketing and consent €200,000

A person who was not (or no longer) a customer received a letter from CaixaBank about an update to its privacy statement, announcing that she would be contacted about her advertising preferences. The Spanish data protection authority (Agencia Española de Protección de Datos, AEPD) considered the continued storage of her data to be an infringement of the principle of storage limitation and imposed 200,000 EUR; the bank's request for reconsideration was dismissed as inadmissible.

What organisations can take from it

Before mass mailings, check whether the recipients' data may still be stored at all – former customers should be deleted, not written to.

Authority / court
Agencia Española de Protección de Datos (AEPD)
Area of law
Data protection · Marketing and consent
Legal basis
Art. 5 Abs. 1 lit. e DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer identification (KYC)

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

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

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30 Apr 2025 Bondora ASBondora must pay 200,000 EUR for breaching responsible lending rules EstoniaConsumer protection and online retail €200,000

From 6 December 2023 to 24 February 2024, Bondora concluded consumer credit agreements without assessing all criteria provided for by law and satisfying itself of the borrowers’ ability to repay. In misdemeanour proceedings, the Finantsinspektsioon (Estonian Financial Supervision Authority) imposed 200,000 EUR. Date = publication.

What organisations can take from it

Automated credit decisions do not release lenders from the full statutory creditworthiness assessment.

Relevance to training and awareness

Responsible lending

Authority / court
Finantsinspektsioon (Estnische Finanzaufsicht)
Area of law
Consumer protection and online retail
Legal basis
§ 99 Abs. 2 KAVS
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
30 Apr 2025

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

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14 Apr 2025 Iberinform Internacional, S.A.AEPD: 720,000 EUR against business information agency Iberinform for purchased data on entrepreneurs SpainData subject rights and transparency €720,000

Since 2008, Iberinform had obtained data on sole traders through a supply contract with Camerdata and used it to enrich its own files for commercial information services. The Spanish data protection authority (Agencia Española de Protección de Datos, AEPD) found no legal basis for this and no information of the data subjects, and imposed 360,000 EUR for each (720,000 EUR in total) as well as an order to bring the processing into compliance; the request for reconsideration (recurso de reposición) was rejected.

What organisations can take from it

Companies that purchase personal data from third parties need their own legal basis and must actively inform the data subjects.

Authority / court
Agencia Española de Protección de Datos (AEPD)
Area of law
Data protection · Data subject rights and transparency
Legal basis
Art. 6 Abs. 1, Art. 14 DSGVO
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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10 Apr 2025 Block, Inc.NYDFS: 40 million USD against Block (Cash App) over AML deficiencies USA, NYCustomer due diligence €36.1m

The New York State Department of Financial Services (NYDFS) imposed 40 million USD on the operator of Cash App for serious gaps in its BSA/AML programme, including insufficient customer due diligence, a lack of risk-based controls and untimely transaction monitoring. Rapid growth in 2019/2020 led to a considerable backlog of alerts; an independent monitor is being appointed.

What organisations can take from it

Scale compliance capacity with growth – a backlog of alerts is a supervisory infringement in its own right.

Authority / court
New York State Department of Financial Services (NYDFS)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
BSA/AML-, Geldtransfer- und Virtual-Currency-Vorschriften des NYDFS
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
Cooperation and remedial measures already initiated
Published
10 Apr 2025

Original amount 40,000,000 USD, converted at the ECB reference rate of 10 Apr 2025.

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1 Apr 2025 OKCoin Europe LimitedMalta: 1.05 million EUR against crypto exchange OKCoin Europe over anti-money laundering deficiencies MaltaInternal controls €1.05m

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money laundering for crypto-assets

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

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31 Mar 2025 FXNET LimitedCyprus: FXNET pays 225,000 EUR under settlement over organisational and CFD breaches CyprusOrganisational requirements €225,000

The investigation covering 2021 to 2022 concerned compliance organisation, product governance, record-keeping obligations, safeguarding of client funds, client information, suitability and appropriateness assessments and the CFD restrictions for retail investors. Following board resolutions of 17 and 31 March 2025, the Cyprus Securities and Exchange Commission (CySEC) concluded a settlement of 225,000 EUR, which has been paid.

What organisations can take from it

Safeguarding client funds and keeping proper records are basic duties of every investment firm – gaps quickly add up in a settlement.

Authority / court
Cyprus Securities and Exchange Commission (CySEC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 17, 22(1), 25, 26(3)(a) Gesetz über Wertpapierdienstleistungen 2017; Art. 42 VO (EU) 600/2014; Art. 37(4) CySEC-Gesetz
Action
Other
Status of proceedings
final
Sector
Financial services and insurance
Published
11 Nov 2025

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20 Mar 2025 The London Metal Exchange (LME)London Metal Exchange: 9.2 million GBP – controls and escalation failed in nickel turmoil United KingdomCritical infrastructure €11m

When the nickel price rose to over 100,000 USD within just over an hour on 8 March 2022, only junior staff were on duty during Asian trading hours, and they had not been trained to recognise a disorderly market; they did not escalate and even switched off price bands. The Financial Conduct Authority (FCA) imposed a fine on the recognised investment exchange for the first time: 9.2 million GBP after a 30% discount.

What organisations can take from it

Critical infrastructure needs trained staff around the clock and clear escalation paths – including at night and at off-peak times.

Relevance to training and awareness

Escalation of unusual market conditions; training of shift staff

Missing or inadequate training played a role in the decision.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Information security and cyber · Critical infrastructure
Legal basis
FCA REC 2.5.1 (Recognition Requirements); Art. 18 RTS 7 (MiFID II)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Early settlement (30% discount); improvements since March 2022.

Original amount 9,200,000 GBP, converted at the ECB reference rate of 20 Mar 2025.

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

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10 Mar 2025 Οργανισμός Χρηματοδοτήσεως Στέγης (Housing Finance Corporation)Cyprus: 10,000 EUR against housing finance corporation for storing data too long CyprusData subject rights and transparency €10,000

The housing finance corporation retained data of a former customer in its loan system beyond the permissible retention period because deletion there is only possible manually, record by record. The Επίτροπος Προστασίας Δεδομένων Προσωπικού Χαρακτήρα (Commissioner for Personal Data Protection) imposed 10,000 EUR and ordered erasure within 10 days as well as technical and organisational corrections within six months.

What organisations can take from it

Retention periods need technical support – a system without a deletion function turns every expired period into an infringement.

Authority / court
Επίτροπος Προστασίας Δεδομένων Προσωπικού Χαρακτήρα (Commissioner for Personal Data Protection)
Area of law
Data protection · Data subject rights and transparency
Legal basis
Art. 5 Abs. 1 lit. d und e, Art. 24 Abs. 1 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

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

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money laundering in small financial service providers

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

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

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

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

What organisations can take from it

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

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

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

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

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7 Feb 2025 Trust International Insurance Company (Cyprus) LimitedCyprus: reprimand for Trust International Insurance – accident file given to insurance agent CyprusData breaches and data security Reprimand or warning

An insurance agent who was himself involved in an accident received, on request, the roadside assistance file from the insurer, including data of the other party to the accident, and subsequently contacted that person. The Επίτροπος Προστασίας Δεδομένων Προσωπικού Χαρακτήρα (Commissioner for Personal Data Protection) issued a reprimand because there was no legal basis for the disclosure and internal procedures did not cover this case, and ordered a procedure for data requests from agents and employees.

What organisations can take from it

Own agents or employees are also third parties when they request data in their own matters – this must be governed in the disclosure process.

Relevance to training and awareness

Disclosure of customer data to agents and colleagues in their own matters

Authority / court
Επίτροπος Προστασίας Δεδομένων Προσωπικού Χαρακτήρα (Commissioner for Personal Data Protection)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 5 Abs. 1 lit. a und f, Art. 6 Abs. 1, Art. 32 Abs. 1 DSGVO
Action
Reprimand or warning
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The company implemented the order

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

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29 Jan 2025 Cembra Money Bank AGFDPIC ruling: Cembra Money Bank answered access requests too late and in generic terms SwitzerlandData subject rights and transparency Order

From December 2023 to September 2024, Cembra answered 9 of 13 access requests after the 30-day deadline had expired, and responded to all 13 people only with standard letters instead of the data actually processed about them. The Swiss Federal Data Protection and Information Commissioner (Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter, EDÖB) required the bank to provide the data subsequently.

What organisations can take from it

Access requests need a process with resources and deadline monitoring – boilerplate text is no substitute for genuine disclosure of data.

Relevance to training and awareness

Handling access requests

Authority / court
Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB)
Area of law
Data protection · Data subject rights and transparency
Legal basis
DSG Art. 25 Abs. 2 lit. b, Art. 25 Abs. 7
Action
Order
Status of proceedings
final
Sector
Financial services and insurance
Published
1 Jul 2025

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

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23 Jan 2025 PayPal, Inc.NYDFS: $2 million against PayPal over untrained teams and missing MFA USA, NYSecurity measures and risk management €1.92m

When changing data flows for 1099-K tax forms, insufficiently trained teams bypassed security processes; criminals with compromised credentials were able to retrieve forms containing social security numbers. According to the New York State Department of Financial Services (NYDFS), qualified personnel, training, access policies as well as MFA, CAPTCHA and rate limiting were lacking.

What organisations can take from it

Anyone changing data flows must know the security processes – training development teams is part of cyber defence.

Relevance to training and awareness

Secure software development and change processes

Missing or inadequate training played a role in the decision.

Authority / court
New York State Department of Financial Services (NYDFS)
Area of law
Information security and cyber · Security measures and risk management
Legal basis
23 NYCRR Part 500 (Cybersecurity Regulation)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Culpability
negligent
Mitigating circumstances
PayPal has since remedied the deficiencies.
Published
23 Jan 2025

Original amount 2,000,000 USD, converted at the ECB reference rate of 23 Jan 2025.

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

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16 Jan 2025 Two Sigma Investments LP und Two Sigma Advisers LPTwo Sigma: 90 million USD – known weaknesses in investment models left unremedied for years USAOrganisational requirements €87.6m

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.

What organisations can take from it

Model risks need a change and approval procedure – and identified weaknesses need a binding deadline for remediation.

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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13 Jan 2025 BMO Capital Markets Corp.BMO Capital Markets: 40.7 million USD – inadequate supervision of bond desk USAOrganisational requirements €39.9m

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.

What organisations can take from it

Tailor supervisory procedures to the actual products and sales practices of each desk – generic policies are not enough.

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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10 Jan 2025 Εθνική Τράπεζα της Ελλάδος Α.Ε. (National Bank of Greece)Greece: 120,000 EUR against National Bank of Greece after misdirected payment via mobile number GreeceData breaches and data security €120,000

An IRIS transfer made by mobile number via the bank’s app ended up with an uninvolved customer instead of the intended recipient because the number had been assigned incorrectly. By Decision 3/2025, the Αρχή Προστασίας Δεδομένων Προσωπικού Χαρακτήρα (Hellenic Data Protection Authority) imposed 100,000 EUR for inaccurate data, insufficient security, lack of data protection by design and failure to notify the data breach, as well as 20,000 EUR for breach of the right of access.

What organisations can take from it

Even a single misdirected payment can be a notifiable data breach – customer complaints must be assessed internally as a possible incident.

Relevance to training and awareness

Recognising and reporting data breaches

Authority / court
Αρχή Προστασίας Δεδομένων Προσωπικού Χαρακτήρα (Hellenic Data Protection Authority)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 5 Abs. 1 lit. d und f, Art. 15, 25, 32, 33, 34 DSGVO
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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9 Jan 2025 Arian Financial LLPFCA: small broker Arian Financial fined over cum-ex money laundering risks United KingdomInternal controls €344,791

From January to September 2015, the broker had no effective systems against financial crime and was therefore exposed to the risk of facilitating fraudulent trading and money laundering in connection with cum-ex trades. Following proceedings before the Upper Tribunal, the UK Financial Conduct Authority (FCA) set the fine at £288,962.53 instead of the £744,745 originally intended.

What organisations can take from it

Even small brokers must question unusually lucrative, circular trading patterns before executing them.

Relevance to training and awareness

Recognising warning signs in unusual trading structures

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
FCA Principles 2 und 3 (PRIN 2, PRIN 3)
Action
Fine
Status of proceedings
reduced
Sector
Financial services and insurance
Mitigating circumstances
Reduction by the Upper Tribunal
Published
10 Jan 2025

Original amount 288,962.53 GBP, converted at the ECB reference rate of 9 Jan 2025.

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6 Jan 2025 Luxembourg credit institution: 175,000 EUR for late responses to data subject requests LuxembourgData subject rights and transparency €175,000

Following 47 complaints, the Commission nationale pour la protection des données (Luxembourg data protection authority, CNPD) found that a Luxembourg credit institution (pseudonymised in the decision as ‘Société A’) had not responded to data subjects’ requests on time; the CNPD did not accept the reference to the COVID-19 pandemic. It issued a reprimand (rappel à l’ordre) and imposed 175,000 EUR.

What organisations can take from it

Data subject requests require deadline tracking and a monitored DPO mailbox – staff shortages are no excuse.

Relevance to training and awareness

Deadlines for data subject requests

Authority / court
Commission nationale pour la protection des données (CNPD) – formation restreinte
Area of law
Data protection · Data subject rights and transparency
Legal basis
DSGVO Art. 12 Abs. 3 und 4
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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23 Dec 2024 Eurolife LtdCyprus: reprimand for insurer Eurolife – unsealed dismissal letter delivered to father CyprusEmployee data Reprimand or warning

A courier of the insurer delivered an employee’s dismissal letter unsealed to his parents’ home and, when the father refused to accept it, left it there, so that third parties could read its contents. The Επίτροπος Προστασίας Δεδομένων Προσωπικού Χαρακτήρα (Commissioner for Personal Data Protection) issued a reprimand for breaches of lawfulness, confidentiality and accountability and ordered the delivery procedure for dismissal letters to be revised within one month.

What organisations can take from it

HR letters such as dismissals must be sealed and delivered only to the person concerned – couriers need clear instructions.

Relevance to training and awareness

Confidential delivery of HR correspondence

Authority / court
Επίτροπος Προστασίας Δεδομένων Προσωπικού Χαρακτήρα (Commissioner for Personal Data Protection)
Area of law
Data protection · Employee data
Legal basis
Art. 5 Abs. 1 lit. a und f, Art. 6, Art. 24 Abs. 1 DSGVO
Action
Reprimand or warning
Status of proceedings
unknown
Sector
Financial services and insurance

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

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17 Dec 2024 Sambla Group OySambla Group: 950,000 EUR – loan applications accessible via unprotected links FinlandData breaches and data security €950,000

On the loan comparison portals lainaparkki.fi and rahoitu.fi, application data (including income, housing costs, marital status, children) could be accessed by anyone who knew the personal customer link; the links were targeted by phishing and data reached third parties. The sanctions board of the Tietosuojavaltuutetun toimisto (Office of the Data Protection Ombudsman) imposed 950,000 EUR and ordered the data subjects to be notified.

What organisations can take from it

Personal links are not access protection – sensitive customer data requires authentication and regular security testing.

Authority / court
Tietosuojavaltuutetun toimisto – seuraamuskollegio (Datenschutzbeauftragter, Sanktionsgremium)
Area of law
Data protection · Data breaches and data security
Legal basis
DSGVO Art. 5 Abs. 1 lit. f, Art. 25, Art. 32
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
20 Dec 2024

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

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12 Dec 2024 Leonteq AG (Finanzgruppe Leonteq)Leonteq: distribution via unregulated partners – confiscation of 9.3 million CHF in profits SwitzerlandOrganisational requirements €9.98m

The Swiss Financial Market Supervisory Authority (FINMA) found serious breaches of risk management obligations and of the requirement to guarantee irreproachable business conduct: the financial group monitored its distribution chain inadequately and in some cases worked with dubious, unregulated distributors that sold products in countries not intended for them without authorisation. FINMA ordered governance requirements, the termination of these relationships, the appointment of an audit agent and the confiscation of 9.3 million CHF in profits; the ruling was not yet final at the time of publication.

What organisations can take from it

Anyone who distributes via third parties is liable for their regulatory status – sales partners require due diligence just like customers.

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Finanzmarktaufsichtsgesetz (FINMAG)
Action
Disgorgement of profits
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Good cooperation in the proceedings; Leonteq had already strengthened compliance and distribution controls of its own accord and terminated relationships with suspicious distributors

Original amount 9,300,000 CHF, converted at the ECB reference rate of 12 Dec 2024.

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3 Dec 2024 Salva Kindlustuse ASSalva Kindlustus: 10,000 EUR for motor insurance advertising without mandatory notice EstoniaMisleading advertising and pricing €10,000

Through Europark Estonia, the insurer placed advertising for motor third-party liability insurance that lacked the statutory notice referring to the insurance terms, and incorrectly stated on policies that the contracts had been concluded through a registered insurance agent. Fine of 10,000 EUR. Date = publication.

What organisations can take from it

Anyone using distribution partners for advertising and concluding contracts must itself check their mandatory disclosures and registration.

Relevance to training and awareness

Mandatory disclosures in financial advertising; management of distribution partners

Authority / court
Finantsinspektsioon (Estnische Finanzaufsicht)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
§ 254 Abs. 2 KindlTS (Versicherungstätigkeitsgesetz); Werbegesetz
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
3 Dec 2024

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

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26 Nov 2024 Macquarie Bank Limited, London BranchMacquarie Bank London: 13 million GBP – trader concealed over 400 fictitious trades United KingdomOrganisational requirements €15.6m

From June 2020 to February 2022, a trader on the metals and commodities desk was able to book over 400 fictitious trades and circumvent three key internal controls in order to conceal losses; the bank was partly aware of the weaknesses but did not remedy them in time. Unwinding the positions cost around 57.8 million USD; the Financial Conduct Authority (FCA) imposed 13 million GBP on the bank and banned the trader Travis Klein.

What organisations can take from it

Close known control weaknesses in trading with a deadline and a responsible person – otherwise a lone perpetrator becomes an organisational failure.

Relevance to training and awareness

Recognising and reporting circumvention of controls in trading

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
FCA Principles for Businesses, Principle 3 (Systeme und Kontrollen); s. 206 Financial Services and Markets Act 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
Prohibition order imposed on the trader; no fine imposed on him on grounds of serious financial hardship.

Original amount 13,031,400 GBP, converted at the ECB reference rate of 26 Nov 2024.

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

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22 Nov 2024 Banus Port Vagyonkezelő Zrt.Banus Port: 250 million HUF for fictitious trading in 4iG shares HungaryMarket abuse and insider dealing €608,080

From September 2023 to May 2024, the asset management company used transactions worth several billion forints to create false signals about the trading volume of 4iG shares (‘painting the tape’). The Magyar Nemzeti Bank (Central Bank of Hungary, MNB) prohibited any repetition, imposed 250 million HUF and filed a criminal complaint.

What organisations can take from it

Transactions that mainly simulate turnover are market manipulation – even without a price target.

Authority / court
Magyar Nemzeti Bank (MNB)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 12, 15 MAR (Marktmanipulation), Beschluss H-PJ-III-B-26/2024
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
intentional
Published
22 Nov 2024

Original amount 250,000,000 HUF, converted at the ECB reference rate of 22 Nov 2024.

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

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8 Nov 2024 Invesco Advisers, Inc.Invesco Advisers: 17.5 million USD for inflated ESG integration percentages USAMisleading environmental and sustainability claims €16.2m

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.

What organisations can take from it

Sustainability metrics used in sales need a written definition and a traceable calculation.

Relevance to training and awareness

Verifiable metrics in ESG marketing

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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6 Nov 2024 Deželna banka Slovenije d. d.Deželna banka Slovenije: 90,000 EUR for deficient credit risk provisioning SloveniaOrganisational requirements €90,000

From 2018 to mid-2023, the bank had no adequate policies for impairments and provisions under IFRS 9 and the EBA guidelines on credit risk. Banka Slovenije (Bank of Slovenia) imposed 90,000 EUR on the bank and 2,500 EUR each on the chair of the management board and a board member.

What organisations can take from it

In Slovenia, governance deficiencies in risk management are also sanctioned personally against board members.

Authority / court
Banka Slovenije
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 171, Art. 396 Abs. 1 Nr. 19 ZBan-3
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Liability of senior managers
Fines of 2,500 EUR each on the chair of the management board, Marko Rozman, and the board member Barbara Cerovšek Zupančič.

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

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1 Oct 2024 Tradition SEF LLCTradition SEF: 875,000 USD – emergency and security tests not brought before the board USACritical infrastructure €789,284

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.

What organisations can take from it

Contingency plans only count if they are tested regularly and the results are noted by the entire governing body.

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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26 Sep 2024 GQG Partners LLCSEC: GQG Partners pays 500,000 US dollars over NDAs and severance agreement USARetaliation against whistleblowers €448,229

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.

What organisations can take from it

Companies concluding a settlement with a whistleblower may require neither the withdrawal of nor a waiver of reports to authorities.

Relevance to training and awareness

Handling announced reports to authorities in separation negotiations

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.

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9 Sep 2024 TransUnionSEC: TransUnion pays 312,000 US dollars over waivers of whistleblower awards USARetaliation against whistleblowers €282,532

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.

What organisations can take from it

Separation and employment agreements must restrict neither reports to authorities nor the entitlement to whistleblower awards.

Relevance to training and awareness

Whistleblower protection in contract templates (HR/Legal)

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.

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4 Sep 2024 Nationwide Planning Associates, Inc.; NPA Asset Management, LLC; Blue Point Strategic Wealth Management, LLCSEC: Nationwide Planning and partners pay 240,000 US dollars over reporting prohibitions USARetaliation against whistleblowers €217,195

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).

What organisations can take from it

Complaint settlements with clients must not require an assurance not to contact authorities.

Relevance to training and awareness

Whistleblower protection in complaint and settlement processes

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.

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20 Aug 2024 mBank S.A.mBank: 4.05 million PLN for failing to inform customers after misdirected mailing PolandData breaches and data security €950,490

In 2022, an employee of a processor accidentally sent customer documents containing PESEL numbers, identity document, income and credit data to another financial institution; the envelope was returned opened. Despite a notice from the authority, the bank did not notify the data subjects because the recipient was ‘trustworthy’; Poland’s data protection authority (UODO) imposed 4,053,173 PLN and ordered the notification.

What organisations can take from it

Whether data subjects must be informed depends on the risk to them – not on how trustworthy the wrong recipient appears.

Relevance to training and awareness

Misdirected documents and notification of data subjects

Authority / court
Prezes Urzędu Ochrony Danych Osobowych (UODO)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 34 Abs. 1 und 2 DSGVO (DKN.5131.1.2024)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
9 Sep 2024

Original amount 4,053,173 PLN, converted at the ECB reference rate of 20 Aug 2024.

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

The Swiss Financial Market Supervisory Authority (FINMA) found that, for two politically exposed persons, the bank insufficiently clarified the origin and purpose of assets – transactions of more than 300 million USD from a Lebanese state institution between 2002 and 2015 – and only reported them to the reporting office in September 2020. It ordered a review of all PEP relationships, a ban on new PEP relationships until the review is completed and the appointment of an audit agent; the decision was not final at the time of publication (date of the announcement used as decision date).

What organisations can take from it

In PEP relationships, document the origin and purpose of large payments; a report made years later is no report.

Relevance to training and awareness

Dealing with politically exposed persons (PEPs)

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Schweizer Geldwäschereirecht (laut FINMA)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Published
18 Jun 2024

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

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22 May 2024 Intercontinental Exchange, Inc. (ICE) und neun Tochtergesellschaften, u. a. New York Stock Exchange LLCIntercontinental Exchange/NYSE: 10 million USD – cyber attack not reported to the SEC USAIncident reporting obligations €9.23m

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.

What organisations can take from it

Operators of critical market infrastructure need internal reporting channels that pass cyber incidents on to all entities subject to reporting obligations within hours.

Relevance to training and awareness

Internal escalation of cyber incidents to compliance

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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24 Apr 2024 N26 Bank AGBaFin: 9.2 million EUR against N26 over systematically late suspicious activity reports GermanySuspicious activity reports €9.2m

By final decision of 24 April 2024, Germany's Federal Financial Supervisory Authority (BaFin) imposed a fine of 9.2 million EUR on the neobank because it had systematically filed money laundering suspicious activity reports late in 2022.

What organisations can take from it

Send suspicious activity reports to the FIU without delay – systematically late reporting risks fines running into millions.

Relevance to training and awareness

Suspicious activity reports without delay

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
§ 56 Abs. 1 Nr. 69, Abs. 3 GwG (verspätete Verdachtsmeldungen, § 43 Abs. 1 GwG); Bekanntmachung nach § 57 GwG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
21 May 2024

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

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25 Mar 2024 Banque Audi (Suisse) SAFINMA confiscates 3.9 million CHF in profits from Banque Audi (Suisse) SwitzerlandSuspicious activity reports €4.01m

The Swiss Financial Market Supervisory Authority (FINMA) found serious infringements of anti-money laundering rules in PEP relationships: insufficient clarification of the origin of assets, failure to report to the reporting office despite unexplained transaction purposes and a serious breach of the duty to provide information, because a critical internal audit report was not handed over. It confiscated 3.9 million CHF in profits, imposed a capital surcharge of 19 million CHF and a two-year ban on new PEP and high-risk relationships (date of the announcement used as decision date).

What organisations can take from it

Withholding critical audit reports from the supervisory authority considerably aggravates a money laundering case.

Relevance to training and awareness

PEP clarifications and openness towards the supervisory authority

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Schweizer Geldwäschereirecht; Gewinneinziehung und Auskunftspflicht nach Finanzmarktaufsichtsrecht (laut FINMA)
Action
Disgorgement of profits
Status of proceedings
unknown
Sector
Financial services and insurance
Published
25 Mar 2024

Original amount 3,900,000 CHF, converted at the ECB reference rate of 25 Mar 2024.

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

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