Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific and Middle East: 1,929 cases from 40 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.

1case from 1 jurisdiction
€485,944Total of monetary amounts
€485,944Largest single case: China CITIC Bank International Limited
€485,944Median per case with an amount

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When?

per quarter, by date of decision
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Q4 20230–
Q1 20240–
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Q4 20241€485,944
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1 case

6 Dec 2024 China CITIC Bank International LimitedHKMA: HKD 4m fine for China CITIC Bank International over misconfigured rules Hong KongInternal controls €485,944

The HKMA imposed a pecuniary penalty of HKD 4 million on China CITIC Bank International because, in the transaction monitoring system it used from November 2015, 13 of 33 detection rules and two core model rules were not implemented as intended until July 2018, so fewer alerts were generated. For 12 of 30 sampled customers, the bank did not examine the background and purpose of unusual transactions. The HKMA identified the lack of a maker-checker control over system values and inadequate acceptance testing as root causes.

What organisations can take from it

The parameters of a monitoring system belong under maker-checker control and must be tested against the business requirements before going live.

Relevance to training and awareness

Maker-checker controls and testing when configuring monitoring systems

Authority / court
Hong Kong Monetary Authority (HKMA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Section 21(2)(c) Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615); Sections 5(1)(c) und 19(3) Schedule 2 AMLO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Remedial action, no previous disciplinary record under the AMLO and cooperation with the HKMA.
Published
6 Dec 2024

Original amount 4,000,000 HKD, converted at the ECB reference rate of 6 Dec 2024.

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

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