Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,235 cases from 44 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.

654cases from 44 jurisdictions
€9.64bnTotal of monetary amounts (572 cases with an amount)
€1.6bnLargest single case: a major US bank
€1.05mMedian per case with an amount

Click a bar to drill down one level.

Where?

by region

All jurisdictions

  1. USA €6.03bn 63 % · 96 cases
  2. EU €1.53bn 16 % · 247 cases
  3. United Kingdom €940.6m 10 % · 87 cases
  4. Australia €426.4m 4 % · 20 cases
  5. South Korea €235.2m 2 % · 9 cases
  6. Canada €144.6m 2 % · 43 cases
  7. Brazil €120.7m 1 % · 13 cases
  8. United Arab Emirates €73.2m 1 % · 34 cases
  9. Switzerland €41.6m 0 % · 20 cases
  10. Singapore €31.5m 0 % · 10 cases
  11. 7 more€72.3m

What for?

by area of law

All areas of law

  1. Capital markets and financial supervision €2.92bn 30 % · 225 cases
  2. Consumer protection and online retail €2.32bn 24 % · 47 cases
  3. Money laundering and terrorist financing €1.97bn 20 % · 218 cases
  4. Sanctions and export control €1.24bn 13 % · 34 cases
  5. Competition law €400m 4 % · 15 cases
  6. Other €281.5m 3 % · 2 cases
  7. Information security and cyber €209.3m 2 % · 30 cases
  8. Bribery and corruption €108.9m 1 % · 6 cases
  9. Data protection €102.7m 1 % · 64 cases
  10. Environment and sustainability €63.3m 1 % · 7 cases
  11. 2 more€17.9m

Who?

by company
  1. Anonymised companies €6.58bn 68 % · 264 cases
  2. HSBC Bank plc €267.5m 3 % · 1 case
  3. GVA Capital Ltd. €186.3m 2 % · 1 case
  4. Union Standard International Group Pty Ltd; Maxi EFX Global AU Pty Ltd (EuropeFX); BrightAU Capital Pty Ltd (TradeFred) €182.1m 2 % · 1 case
  5. KB Kookmin Bank, Shinhan Bank, Woori Bank, Hana Bank €158.2m 2 % · 1 case
  6. Royal Bank of Canada, Morgan Stanley, HSBC u. a. (5 Banken; Deutsche Bank als Kronzeugin bußgeldfrei) €126.2m 1 % · 1 case
  7. UBS Financial Services Inc. €115.3m 1 % · 2 cases
  8. Xeltox Enterprises Ltd. (Cryptomus) €108.1m 1 % · 1 case
  9. Crédit Agricole Corporate and Investment Bank (Crédit Agricole CIB) €88.2m 1 % · 1 case
  10. Two Sigma Investments LP und Two Sigma Advisers LP €87.6m 1 % · 1 case
  11. 368 more€1.73bn

When?

per year, by date of decision
Trend
PeriodCasesTotal
202247€2.5bn
2023124€3.36bn
2024150€1.01bn
2025202€1.55bn
2026131€1.23bn

654 cases

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 a further settling party are jointly 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
Measures against individuals are not reported here.
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 28 Sep 2026 · Version 3 · Direct link

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17 Sep 2026 PFC Technologies Co., Ltd. (vormals PeopleFund Company)P2P lending platform shared customer data without consent: FSS sanctions PFC South KoreaData protection €45,990

According to the sanctions disclosure of the Financial Supervisory Service (FSS, Korea's financial supervisor), the online lending platform PFC Technologies transferred the resident registration numbers of 8,497 customers to a third party without their consent on 28 September 2022 in order to calculate the error rate of a new service for mortgage customers, and received credit information on the same customers from that third party, likewise without consent (such as the address and official value of their properties); in addition, when the inspection began it had not implemented password rules against easily guessed numbers. The sanction of 17 September 2026 comprises an institutional warning, an administrative fine (과태료) of KRW 24 million and a penalty surcharge (과징금) of KRW 49 million, KRW 73 million in total.

What organisations can take from it

Even for internal tests and quality measurements, customer data may only be passed to third parties with consent or a clear legal basis.

Relevance to training and awareness

Consent for sharing credit data and password rules

Authority / court
Financial Supervisory Service (FSS)
Area of law
Data protection
Legal basis
Art. 19, 32 und 34 Credit Information Use and Protection Act; Art. 16, 28 und 29 Durchführungsverordnung
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
17 Sep 2026

Original amount 73,000,000 KRW, converted at the ECB reference rate of 17 Sep 2026.

Checked against the official source on 4 Oct 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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11 Sep 2026 Capitec Bank LimitedCapitec Bank: ZAR 28m for failings in customer due diligence and training South AfricaCustomer due diligence €1.49m

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

What organisations can take from it

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

Relevance to training and awareness

Ongoing due diligence and regular anti-money laundering training

Missing or inadequate training played a role in the decision.

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

KYC and transaction monitoring at payment service providers

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

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

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25 Aug 2026 Kommunal Landspensjonskasse Gjensidig Forsikringsselskap (KLP)KLP: binding commitments after suspected abuse in municipal pensions NorwayAbuse of market power Order

Konkurransetilsynet (Norwegian Competition Authority) made commitments offered by KLP binding and thereby closed its investigation into a possible abuse of a dominant position in public occupational pensions for municipalities. The authority was concerned that, from 2019, when a competitor entered the market, KLP had systematically discouraged municipalities from putting their occupational pension schemes out to tender; KLP now undertakes to refrain from such influence and to remedy the effects of its earlier practice. No infringement was conclusively established and no fine was imposed.

What organisations can take from it

Dominant companies must not use close customer relationships to deter customers from running tenders – even a suspicion of this can lead to binding obligations.

Relevance to training and awareness

Conduct of dominant companies towards public purchasers

Authority / court
Konkurransetilsynet
Area of law
Competition law · Abuse of market power
Legal basis
§ 12 Abs. 3 i. V. m. § 11 konkurranseloven; Art. 54 EWR-Abkommen
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Published
2 Sep 2026

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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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
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 28 Sep 2026 · Version 2 · Direct link

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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12 Aug 2026 Lebes Financeira S.A. – Sociedade de Crédito, Financiamento e InvestimentoLebes Financeira: BRL 2.58m over lending to a related party above the limit BrazilOrganisational requirements €432,774

The BCB (central bank) sanctions committee COPAS imposed a fine of BRL 2,576,000.00 on Lebes Financeira S.A. – Sociedade de Crédito, Financiamento e Investimento because from January 2022 to March 2023 it engaged in prohibited credit transactions with a related company: its banking correspondent retained collected loan instalments, and the arrears reached BRL 147m at the end of November 2022, or 207.66% of adjusted equity against a limit of 10%. In addition there was a BRL 20m loan routed through a third company. The decision is not final.

What organisations can take from it

If an affiliated distribution partner retains customer money, this can quickly become a prohibited loan to a related party.

Authority / court
Banco Central do Brasil (Comitê de Decisão de Processo Administrativo Sancionador – COPAS)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Lei 13.506/2017, Art. 3 II; Lei 4.595/1964, Art. 34 § 3 V d und § 4 I; Resolução CMN 4.693/2018, Arts. 5, 6 und 7 II
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.

Original amount 2,576,000 BRL, converted at the ECB reference rate of 12 Aug 2026.

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

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11 Aug 2026 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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11 Aug 2026 Fiducian Investment Management Services LimitedFiducian: 7.3 million AUD for misleading ESG claims about an ethical fund AustraliaMisleading environmental and sustainability claims €4.47m

The Supreme Court of New South Wales, on application by the Australian Securities and Investments Commission (ASIC, Australia's corporate, markets and financial services regulator), imposed penalties totalling 7.3 million AUD on the fund manager: 2.3 million AUD for misleading statements (s 12DF ASIC Act) and 5 million AUD for breaching its duty of care and diligence as responsible entity (s 601FC(1)(b) Corporations Act). Between October 2019 and May 2024 the Diversified Social Aspirations Fund, marketed as socially responsible, held through underlying funds interests in companies that derived revenue from fossil fuels, among others, even though the product documents promised certain exclusions and ongoing monitoring; the company did not respond to investor concerns by amending its statements.

What organisations can take from it

A fund's sustainability promises require ongoing checks of its actual holdings; where they diverge, either the holdings or the statements must be changed.

Relevance to training and awareness

Substantiating ESG and ethical claims in product documents and fund marketing

Missing or inadequate training played a role in the decision.

Authority / court
Supreme Court of New South Wales (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
ASIC Act 2001 (Cth) s 12DF (Geldbuße nach s 12GBB); Corporations Act 2001 (Cth) s 601FC(1)(b) (Geldbuße nach s 1317G)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Repeat case
no
Mitigating circumstances
Admissions, cooperation throughout the proceedings and contrition; since the proceedings began, an independent review of the product documents; no previous court findings.
Liability of senior managers
According to the agreed facts, senior management was involved (the company's then Executive Chair and Head of Investments).
Published
12 Aug 2026

Original amount 7,300,000 AUD, converted at the ECB reference rate of 11 Aug 2026.

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

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

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

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

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

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

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5 Aug 2026 Powszechna Kasa Oszczędności Bank Polski S.A. (PKO BP)PKO BP: PLN 47.5m for failings in structured deposits PolandOrganisational requirements €11m

The KNF imposed five fines totalling PLN 47,500,000 on PKO BP in connection with structured deposits: PLN 26m for failing to inform clients of existing conflicts of interest, PLN 8m each for not analysing costs and charges and for an imprecise definition of the risk category and target market, PLN 4m for selling without checking target-market suitability and PLN 1.5m for misleading sales material on two products. The decision is not final.

What organisations can take from it

Firms selling structured products must disclose conflicts of interest, test costs against client benefit and define the target market precisely.

Relevance to training and awareness

Conflicts of interest and product governance for retail investment products

Authority / court
Komisja Nadzoru Finansowego (KNF)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 88c Abs. 1 und 2, Art. 88m Abs. 5 und 9 Prawo bankowe i. V. m. Verordnung des Finanzministers vom 21.01.2019 über Dienstleistungen der Banken bei strukturierten Einlagen
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 47,500,000 PLN, converted at the ECB reference rate of 5 Aug 2026.

Checked against the official source on 28 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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31 Jul 2026 UBS Financial Services Inc.UBS Financial Services: 8 million USD over gaps in anti-money laundering monitoring USAOrganisational requirements €6.97m

The CFTC fined the futures commission merchant 8 million USD for failing to supervise diligently the configuration and operation of its anti-money laundering transaction monitoring. From January 2019 to June 2023, thousands of foreign currency wire transfers through retail customers' commodity accounts were insufficiently monitored or not monitored at all: first because of an incomplete manual report which UBS, contrary to commitments made in earlier proceedings in 2018, replaced only more than two years later, and then because of incorrectly fed data in the new automated system. FinCEN, the SEC and FINRA announced their own settlements with UBS Financial Services at the same time. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Commitments made in earlier supervisory proceedings must be implemented on time, and new monitoring systems must be tested for complete data feeds before going live.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
CFTC Regulation 166.3 (17 C.F.R. § 166.3)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
The CFTC recognised the remediation described; according to the order, the core problems of the automated system had been fixed by the fourth quarter of 2022.
Published
3 Aug 2026

Original amount 8,000,000 USD, converted at the ECB reference rate of 31 Jul 2026.

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

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28 Jul 2026 Luk Fook Securities (HK) LimitedLuk Fook Securities: HKD 2.1m fine for weak cybersecurity ahead of ransomware attack Hong KongSecurity measures and risk management €235,595

Luk Fook Securities (HK) was publicly reprimanded and fined 2,100,000 HKD because inadequate cybersecurity controls might have contributed to a ransomware attack on 19 September 2022 hitting numerous core servers and to full recovery taking until 7 October 2022; during that time clients could not trade via the app or internet platform. Findings included missing firewall protection, outdated operating systems and antivirus software, weak access and password controls with credentials stored unencrypted, insufficient controls over remote access and external devices, inadequate data backup and a last security training session in 2018.

What organisations can take from it

Basic cyber hygiene – patching, access and password controls, backups and regular staff training – is a regulatory obligation for financial firms.

Relevance to training and awareness

Ransomware defence, password security and security awareness training

Missing or inadequate training played a role in the decision.

Authority / court
Securities and Futures Commission (SFC)
Area of law
Information security and cyber · Security measures and risk management
Legal basis
s. 194 SFO (Cap. 571); Code of Conduct GP 2, GP 3, GP 7, paras. 12.1, 18.5 und Schedule 7; Guidelines for Reducing and Mitigating Hacking Risks Associated with Internet Trading
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Root-cause review with an independent reviewer, strengthened controls, no evidence of client loss, cooperation, clean disciplinary record.
Published
28 Jul 2026

Original amount 2,100,000 HKD, converted at the ECB reference rate of 28 Jul 2026.

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money-laundering: investigating conspicuous inflows and documentation

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

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

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

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27 Jul 2026 China Industrial Securities International Asset Management LimitedSFC: HKD 6.8m fine for CISIAM over missed red flags in a private fund Hong KongOrganisational requirements €761,367

The SFC publicly reprimanded China Industrial Securities International Asset Management (CISIAM) and fined it HKD 6.8 million because, between August 2019 and September 2020, the manager of a private fund set up for the insurer Tahoe Life acquired complex structures with notes linked to bonds of a related company at the request of the insurer's chief investment officer, without identifying and properly examining the red flags. CISIAM also failed to observe the fund's investment restrictions and objectives and did not manage its risks effectively. In setting the penalty, the SFC also took into account management fees of around HKD 1.9 million received from the fund.

What organisations can take from it

A fund manager must independently assess an investor's instructions and must not implement unusually complex structures without a clear commercial rationale unchecked.

Relevance to training and awareness

Recognising red flags in investor-driven fund arrangements

Missing or inadequate training played a role in the decision.

Authority / court
Securities and Futures Commission (SFC), Hongkong
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Section 194 Securities and Futures Ordinance (Cap. 571); General Principle 2 Code of Conduct; Paragraphen 1.2(d), 3.1 und 3.11.1 Fund Manager Code of Conduct; Abschnitt VIII Management, Supervision and Internal Control Guidelines
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Remedial measures (new policies on risk management and dubious investment arrangements, compliance training), cooperation with the SFC and an otherwise clean disciplinary record.
Published
27 Jul 2026

Original amount 6,800,000 HKD, converted at the ECB reference rate of 27 Jul 2026.

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

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27 Jul 2026 Bright Smart Securities International (H.K.) LimitedBright Smart Securities: HKD 2.8m fine for inadequate wash-trade controls Hong KongMarket abuse and insider dealing €313,504

Bright Smart Securities International (H.K.) was publicly reprimanded and fined 2,800,000 HKD because between November 2023 and September 2025 its controls did not prevent 615 clients from executing 1,021 pairs of wash trades (trades without a change in beneficial ownership) in 736 shares and warrants. Monitoring was mostly after the event and manual, and several wash trades by one client on the same day counted as a single occurrence. Similar deficiencies had been identified and raised repeatedly before but were not fully remedied in any instance.

What organisations can take from it

Trade surveillance must intercept wash trades automatically before execution; after-the-event manual reviews are not enough for recurring patterns.

Relevance to training and awareness

Detecting and preventing wash trades

Authority / court
Securities and Futures Commission (SFC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
s. 194 SFO (Cap. 571); Code of Conduct GP 2, para. 4.3
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Enhanced systems and a commitment to an independent effectiveness review, cooperation.
Published
27 Jul 2026

Original amount 2,800,000 HKD, converted at the ECB reference rate of 27 Jul 2026.

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

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27 Jul 2026 Equity for Growth (Securities) Limited (in liquidation)FCA: Public censure for Equity for Growth (Securities) over misleading minibond promotions United KingdomMisleading advertising and pricing Reprimand or warning

The FCA publicly censured the corporate finance firm Equity for Growth (Securities) Limited. The FCA found that between January 2018 and August 2019 the firm approved seven information memoranda for four unregulated minibond issuers as financial promotions. In the FCA's view, these documents omitted key information, such as the level and range of commissions, so investors could not properly assess the risk. Because the firm was wound up by the court in March 2026 on the FCA's petition, no fine was imposed; the FCA stated that it would otherwise have been £386,467 (including disgorgement).

Authority / court
Financial Conduct Authority (FCA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
COBS 4.2.1(1)R; section 205 FSMA 2000 (Public Censure)
Action
Reprimand or warning
Status of proceedings
final
Sector
Financial services and insurance

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Compliance with cease-and-desist orders and KYC obligations

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

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

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

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

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

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

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

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17 Jul 2026 80 Eight South Africa (Pty) Ltd (vormals Ela Asset Management (Pty) Ltd)80 Eight South Africa: failing to protect clients against fraud South AfricaOrganisational requirements Fine

The financial services provider had not made sure that its clients were protected against losses from theft, fraud or other dishonest acts by its employees; one individual's misconduct caused clients substantial losses. The company was directed to introduce, within two months, a policy protecting against such risks. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Financial services providers need effective controls against fraud by their own employees – even contraventions they discover and report themselves can lead to a penalty and directives.

Relevance to training and awareness

Insider fraud and internal controls

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Sections 2 und 11 General Code of Conduct for Authorised Financial Services Providers and Representatives (2003); Section 13(3)(a) Financial Advisory and Intermediary Services Act 37 of 2002; Section 42(1) Determination of Fit and Proper Requirements for Financial Services Providers (2017)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
According to the authority's update of 22 July 2026, the company had itself discovered and reported the contraventions, which occurred in 2021.
Liability of senior managers
Measures against individuals are not set out here.
Published
17 Jul 2026

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

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16 Jul 2026 Swedbank AB (publ) (mit New York Branch)NYDFS: USD 50 million against Swedbank for withholding information USA, New YorkDisclosure and reporting obligations €43.6m

The NYDFS imposed a penalty of USD 50 million on Swedbank AB (publ) and its New York branch. In response to several requests by the regulator under section 37 of the New York Banking Law concerning links between its Baltic subsidiaries and the law firm Mossack Fonseca (Panama Papers) and the status of European investigations, the bank did not provide the requested information, in breach of section 125(3) of the New York Banking Law. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Information requests from the regulator must be answered in full; withholding information is sanctioned in its own right.

Relevance to training and awareness

Complete and truthful disclosures to the regulator

Authority / court
New York State Department of Financial Services (NYDFS)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
New York Banking Law § 125(3) i. V. m. § 37; Sanktion nach Banking Law §§ 39, 44
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
According to the order, the bank has since, among other things, dismissed its then Chief Compliance Officer and its former CEO and parted ways with numerous other employees; the majority of the board has been replaced.
Published
16 Jul 2026

Original amount 50,000,000 USD, converted at the ECB reference rate of 16 Jul 2026.

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

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16 Jul 2026 HDI Global SEPRA: £4.165m fine on HDI Global SE for inaccurate data on the FSCS compensation scheme United KingdomDisclosure and reporting obligations €4.91m

The PRA fined HDI Global SE, an insurer headquartered in Hanover that operates in the UK through a branch, 4,165,000 GBP. Between August 2021 and August 2024 the firm repeatedly submitted incorrect data on liabilities protected by the FSCS and on the FSCS levy tariff, including in supposedly corrected submissions; it lacked written procedures, clear accountability and internal oversight, and before summer 2023 it did not consult the PRA's rules and guidance.

What organisations can take from it

Returns used to calculate levies need documented calculation procedures and independent review – especially where corrections are submitted.

Authority / court
Prudential Regulation Authority (PRA), Bank of England
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
PRA Fundamental Rules 2 und 6; s. 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
negligent
Mitigating circumstances
Detailed account under the Early Account Scheme, settlement with a 30% discount (otherwise 5,950,000 GBP), corrected historical data and additional FSCS levies paid; in the PRA's view the breaches were neither deliberate nor reckless.
Published
20 Jul 2026

Original amount 4,165,000 GBP, converted at the ECB reference rate of 16 Jul 2026.

Checked against the official source on 3 Oct 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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3 Jul 2026 ASX LimitedASX: 20.5 million AUD for misleading announcement on CHESS replacement project AustraliaDisclosure and reporting obligations €12.4m

The Federal Court of Australia, on application by the Australian Securities and Investments Commission (ASIC, Australia's corporate, markets and financial services regulator), imposed a penalty of 20.5 million AUD on the exchange operator because a market announcement of 10 February 2022 stated that the project to replace its CHESS clearing and settlement system was progressing well. About six weeks later ASX announced a likely delay and paused the project in November 2022; in June 2026 it admitted contraventions of ss 12DA and 12DB of the ASIC Act.

What organisations can take from it

Progress updates on major projects must reflect the actual status, including known risks – and operators of critical market infrastructure are held to a particularly high standard.

Relevance to training and awareness

Accuracy and balance of market announcements about ongoing major projects

Authority / court
Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Australian Securities and Investments Commission Act 2001 (Cth) ss 12DA, 12DB(1)(a) und (e)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
3 Jul 2026

Original amount 20,500,000 AUD, converted at the ECB reference rate of 3 Jul 2026.

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

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2 Jul 2026 IRB-Brasil Resseguros S.A.IRB-Brasil Resseguros: BRL 6.32m settlement over obstructing SUSEP supervision BrazilBribery and corruption €1.07m

IRB-Brasil Resseguros S.A. concluded a Termo de Compromisso (settlement in sanction proceedings) with the CGU and allegedly pays a fine of BRL 6,317,473.41 because the company had hindered the investigative and supervisory activity of the insurance supervisor SUSEP (Art. 5 V Lei 12.846/2013). The fine equals the statutory minimum of 0.1% of gross revenue (BRL 6,509,921.81) less BRL 192,448.40 already paid in SUSEP proceedings over inconsistent reporting. Extraordinary publication was waived, and the proceedings are thereby closed.

What organisations can take from it

Incomplete or inconsistent information given to a supervisory authority can, as obstruction of supervision, trigger an anti-corruption fine.

Relevance to training and awareness

Obstructing supervisory authorities through inaccurate information

Authority / court
Controladoria-Geral da União (CGU)
Area of law
Bribery and corruption
Legal basis
Lei 12.846/2013, Art. 5 V, Art. 6 I; Decreto 11.129/2022, Art. 25 § 2; Portaria Normativa CGU 155/2024
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Credit was given for a compliance programme (3.6%), the absence of proof of advantage or damage (1%) and settlement-related reductions for cooperation and admission; fines already paid to SUSEP were deducted.
Published
3 Jul 2026

Original amount 6,317,473.41 BRL, converted at the ECB reference rate of 2 Jul 2026.

Checked against the official source on 3 Oct 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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30 Jun 2026 Curtis Faraday LimitedFCA bars debt adviser Curtis Faraday from taking new customers over consumer risks United KingdomOrganisational requirements Order

The FCA barred the debt advice firm Curtis Faraday Limited with immediate effect from accepting new customers or referrals for debt, insolvency and IVA-related activities and required it to refer existing customers to other advice providers. Based on file reviews and call recordings, the FCA saw indications that customers' financial information was distorted during the advice process, that the business model, with close links to insolvency service providers, created conflicts of interest and a bias towards commission-generating solutions, that staff circumvented controls and that the firm repeatedly gave the FCA incomplete or inconsistent information.

What organisations can take from it

Debt advice must be impartial: commission incentives and close links to debt solution providers require effective controls against product bias.

Relevance to training and awareness

Impartial advice and handling conflicts of interest

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
s. 55L(3)(a) FSMA 2000; Threshold Conditions nach Schedule 6 FSMA (paras. 2C, 2D, 2E und 2F)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance

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

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26 Jun 2026 Netrios LP Ltd.; Red Acre Ltd.Netrios and Red Acre: 2.5 million USD for white-label leveraged trading with US retail customers USAOrganisational requirements €2.19m

The CFTC fined Netrios LP Ltd., incorporated in Saint Lucia, 1,750,000 USD and Maltese Red Acre Ltd. 750,000 USD, totalling 2,500,000 USD. From 2019 to September 2025, Netrios sold a white-label service (website, trading software, margin accounts, execution, back office) through which offshore platforms offered US retail customers who were not eligible contract participants leveraged forex, precious metals, crypto and equity transactions outside a registered exchange; Red Acre assisted with customer support and marketing. The SEC took parallel action over the same conduct. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Technology and service providers share liability if their platform solution enables US retail customers to trade on leverage unlawfully outside registered exchanges.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Section 4(a) Commodity Exchange Act (7 U.S.C. § 6(a)); Beihilfe nach Section 13(a) (7 U.S.C. § 13c(a))
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
29 Jun 2026

Original amount 2,500,000 USD, converted at the ECB reference rate of 26 Jun 2026.

Checked against the official source on 3 Oct 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 Bourse Direct SAAMF: EUR 800,000 on online broker Bourse Direct over reporting and monitoring failures FranceDisclosure and reporting obligations €800,000

According to the AMF (Autorité des marchés financiers, French financial markets authority) Enforcement Committee, the online broker Bourse Direct did not properly submit its transaction reports under Art. 26 MiFIR between January 2021 and November 2023 and did not maintain an adequate system to detect and report suspicious orders and transactions under Art. 16(2) MAR. The company received EUR 800,000. The amount covers only the sanction imposed on the company.

What organisations can take from it

Investment firms should regularly test transaction reporting and market abuse surveillance for completeness and effectiveness.

Relevance to training and awareness

Transaction reporting and market abuse surveillance at brokers

Authority / court
Autorité des marchés financiers (AMF), Commission des sanctions
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 26 Verordnung (EU) Nr. 600/2014 (MiFIR); Art. 15 Delegierte Verordnung (EU) 2017/590; Art. 16 Abs. 2 Verordnung (EU) Nr. 596/2014 (MAR); Art. 2, 3 Delegierte Verordnung (EU) 2016/957
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
50 to 249
Published
25 Jun 2026

Checked against the official source on 2 Oct 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 Banque Internationale à Luxembourg S.A.Banque Internationale à Luxembourg: €3.255m ECB penalty for breaching a model decision EU levelOrganisational requirements €3.26m

From 2 October 2023 to 22 October 2024, contrary to a 2023 ECB decision, Banque Internationale à Luxembourg did not apply the newly approved internal models for the expected loss best estimate (ELBE) of defaulted retail and corporate exposures and therefore reported an IRB shortfall to be deducted from Common Equity Tier 1 capital that was too small. The ECB regarded the breach as intentional and severe and imposed 3,255,000 EUR; remedial action was taken into account as mitigating.

What organisations can take from it

Supervisory decisions on internal models must be implemented on time, even if the previous approach produces more favourable capital figures.

Relevance to training and awareness

Timely implementation of supervisory decisions

Authority / court
Europäische Zentralbank (EZB), Bankenaufsicht
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 18 Abs. 7 VO (EU) Nr. 1024/2013 (Verstoß gegen einen EZB-Beschluss zu internen Modellen)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Mitigating circumstances
Remedial action to alleviate the effects and to prevent future breaches.
Published
29 Jun 2026

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Register checks and follow-up on identified KYC gaps

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

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

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19 Jun 2026 moomoo証券株式会社moomoo Securities: three months without new accounts after false NISA information and AML gaps JapanOrganisational requirements Order

From February to May 2025 the online broker wrongly displayed at least 77 US ETFs and ETNs as eligible for NISA (59 clients traded 25 of them in the tax-advantaged account) and repeated this for a further security after discovery, handled affected clients carelessly and unequally, had since 2024 refused all transfers of holdings to other institutions, carried out no suspicious-transaction assessment for at least 1,531 rejected account applicants and managed cyber and system risks inadequately. Soliciting and accepting new accounts was prohibited from 19 June to 18 September 2026, together with a business improvement order.

What organisations can take from it

A firm that grows fast with account-opening bonuses must scale product approval, complaints handling, suspicious-transaction checks and IT security at the same pace.

Relevance to training and awareness

Accurate product information and suspicious-transaction checks also for rejected clients

Missing or inadequate training played a role in the decision.

Authority / court
Kanto Local Finance Bureau (関東財務局) auf Empfehlung der Securities and Exchange Surveillance Commission (SESC, 証券取引等監視委員会)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Financial Instruments and Exchange Act (FIEA, 金融商品取引法) Art. 52 Abs. 1, Art. 51; Art. 38 Nr. 1, Art. 43, Art. 40 Nr. 2 FIEA i. V. m. Art. 123 Abs. 1 Nr. 14 Cabinet Office Order on Financial Instruments Business; Act on Prevention of Transfer of Criminal Proceeds (犯罪収益移転防止法)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Published
19 Jun 2026

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

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18 Jun 2026 HSBC Bank Australia LimitedHSBC Bank Australia: AUD 35m penalty for failing to protect customers from scams AustraliaOrganisational requirements €21.4m

HSBC admitted that from May 2023 to May 2024 it lacked adequate controls against unauthorised payments via its internal transfer channel, that from January 2020 it handled scam reports under the ePayments Code too slowly (144 days on average) and without applying the liability rules, and that until April 2024 it gave affected customers no orderly way back into their accounts. The Court imposed AUD 35 million (AUD 10 million for the fraud controls, AUD 22.5 million for the contraventions relating to the ePayments Code, AUD 2.5 million for restoring account access) and ordered notices on the website, in the app and in letters to customers.

What organisations can take from it

Banks must deploy scam controls on every payment channel and handle scam reports within the deadlines of the applicable rules.

Relevance to training and awareness

Fraud and scam prevention in payments and handling of customer scam reports

Authority / court
Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
s 912A(1)(a), (5A) Corporations Act 2001 (Cth); s 47(1)(a), (4) National Consumer Credit Protection Act 2009 (Cth)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Admissions and jointly proposed penalty; remediation programme with payments of AUD 27,915,700.56 by 21 May 2026; no previous contraventions of a similar nature.
Liability of senior managers
According to the agreed facts, senior management was also aware before May 2023 of heightened fraud risks and gaps in the controls.
Published
18 Jun 2026

Original amount 35,000,000 AUD, converted at the ECB reference rate of 18 Jun 2026.

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Enhanced due diligence for high-risk customers

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Licensing requirement and KYC for cross-border crypto services

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

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

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17 Jun 2026 Peken Global Limited (KuCoin)VARA: fine and cease-and-desist order against unlicensed Peken Global (KuCoin) United Arab EmiratesCapital markets and financial supervision Fine

Following VARA investigations, Peken Global Limited, trading as KuCoin, provided virtual asset broker-dealer and/or exchange services to customers in Dubai without a licence. VARA imposed fines of an undisclosed amount and ordered the immediate cessation of all unlicensed activities; other group entities were expressly not affected.

What organisations can take from it

Anyone providing crypto services cross-border to customers in Dubai needs a licence there – regardless of where the platform is based.

Relevance to training and awareness

Licensing requirement for crypto services in the target market

Authority / court
Virtual Assets Regulatory Authority (VARA), Dubai
Area of law
Capital markets and financial supervision
Legal basis
Federal Decree Law No. (10) of 2025 (AML/CFT/PF); Dubai Law No. (4) of 2022 Regulating Virtual Assets; Cabinet Resolution No. 111/2022; VARA Regulations und Rulebooks
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Full cooperation and full compliance with the measures; intention to go through the licensing process.
Published
24 Jun 2026

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

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16 Jun 2026 Banco BPM S.p.A.; Banco BPM Vita S.p.A.CONSOB fines Banco BPM and BPM Vita €570,000 over delayed disclosure of ECB letter ItalyDisclosure and reporting obligations €570,000

The CONSOB (Italian securities regulator) fined Banco BPM S.p.A. 370,000 EUR, of which 170,000 EUR for late disclosure of inside information under Art. 17(1) MAR and 200,000 EUR for obstructing supervision under Art. 187-quinquiesdecies of the Consolidated Law on Finance (TUF), and fined its subsidiary Banco BPM Vita S.p.A. 200,000 EUR, 570,000 EUR in total. In connection with BPM Vita's tender offer for Anima Holding S.p.A., the bank disclosed an ECB letter of 21 March 2025 rejecting the application of the so-called Danish Compromise to CONSOB and the market only four days later, after two trading days of the acceptance period. Both companies had previously informed CONSOB only incompletely about their discussions with the ECB.

What organisations can take from it

Supervisory decisions affecting an ongoing takeover bid must be disclosed to the market and the supervisor at once rather than weighed internally.

Relevance to training and awareness

Ad hoc disclosure and transparency towards the supervisor in takeovers

Authority / court
CONSOB (Commissione Nazionale per le Società e la Borsa)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 17 Abs. 1 Verordnung (EU) 596/2014 (MAR); Art. 187-ter.1 und Art. 187-quinquiesdecies Abs. 1 und 1-ter D.Lgs. 58/1998 (TUF)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Repeat case
yes
Published
23 Jun 2026
Sources

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11 Jun 2026 Union Standard International Group Pty Ltd; Maxi EFX Global AU Pty Ltd (EuropeFX); BrightAU Capital Pty Ltd (TradeFred)Union Standard and two CFD intermediaries: record penalties of AUD 300.2m AustraliaConsumer protection and online retail €182.1m

Between 2018 and 2020 the since-collapsed CFD issuer Union Standard and its two authorised representatives EuropeFX and TradeFred pushed inexperienced and vulnerable customers into trading risky contracts for difference using aggressive sales tactics; customers lost more than AUD 83 million, while in most cases the representatives profited from those losses. The Court imposed AUD 156.7 million on Union Standard, AUD 114.1 million on EuropeFX and AUD 29.4 million on TradeFred, together with a permanent ban on EuropeFX and an obligation for it to refund customers’ net deposits. For the first time a licensee was also penalised for distributing CFDs to customers in China although it knew or ought to have known of their legal risk.

What organisations can take from it

Licensees cannot outsource responsibility for distribution through authorised representatives and must actively monitor their sales practices.

Relevance to training and awareness

Licensees’ responsibility for authorised representatives and distribution of complex leveraged products to retail clients

Authority / court
Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Consumer protection and online retail
Legal basis
ASIC Act 2001 (Cth): Verbot von unconscionable conduct und irreführenden Angaben; Corporations Act 2001 (Cth): Pflicht des Lizenzinhabers zu effizienter, ehrlicher und fairer Leistungserbringung
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
12 Jun 2026

Original amount 300,200,000 AUD, converted at the ECB reference rate of 11 Jun 2026.

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

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11 Jun 2026 Deutsche Bank AktiengesellschaftDeutsche Bank AG: AUD 2m penalty for inaccurate derivative trade reporting AustraliaDisclosure and reporting obligations €1.21m

ASIC issued an infringement notice because on 208 business days between October 2024 and August 2025 Deutsche Bank had not accurately reported the “direction” fields for 20,483 outstanding and 244,091 terminated or matured OTC derivative transactions, mostly foreign exchange trades, to trade repositories. The bank allegedly paid AUD 2 million under the infringement notice; payment is not an admission of guilt.

What organisations can take from it

Derivative reporting systems need plausibility checks on mandatory fields, otherwise individual errors add up to systemic breaches.

Relevance to training and awareness

Data quality in regulatory transaction reporting

Authority / court
Australian Securities and Investments Commission (ASIC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Rule 2.2.6 ASIC Derivative Transaction Rules (Reporting) 2024; reg 7.5A.104 Corporations Regulations 2001
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
Cooperation with ASIC and measures to prevent further reporting errors.
Published
13 Jul 2026

Original amount 2,000,000 AUD, converted at the ECB reference rate of 11 Jun 2026.

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

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

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

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Internal controls in the AML programmes of crypto service providers

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

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

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3 Jun 2026 Wendelspiess Partners AG in LiquidationFINMA: Wendelspiess Partners breached FIDLEG duties, licence revoked SwitzerlandOrganisational requirements Order

Wendelspiess Partners AG invested almost all the money of its more than 400 clients in a barely diversified foreign fund it had set up and managed itself, which invested mainly in a Zug-based investment company and companies linked to it; it gave insufficient information about conflicts of interest and risks, carried out no suitability check and withheld relevant information from the Eidgenössische Finanzmarktaufsicht (FINMA, Swiss Financial Market Supervisory Authority). FINMA revoked the licence as an asset manager of the company, which is now bankrupt. Measures against individuals are not set out here. The decision is not final.

What organisations can take from it

In-house funds in client portfolios are a classic conflict of interest that must be disclosed and backed by a documented suitability check.

Relevance to training and awareness

Conflicts of interest with in-house funds; information and suitability duties

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Verhaltenspflichten nach dem Finanzdienstleistungsgesetz (FIDLEG): Interessenkonflikte, Information, Eignungsprüfung; Auskunftspflicht gegenüber der FINMA
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
3 Jun 2026

Checked against the official source on 5 Oct 2026 · Version 3 · Direct link

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2 Jun 2026 bunq B.V.AFM: €170,000 fine for bunq over late replies to fraud complaints NetherlandsOrganisational requirements €170,000

On 2 June 2026 the Autoriteit Financiële Markten (AFM, Dutch Authority for the Financial Markets) fined bunq B.V. 170,000 EUR because in seven cases the bank did not give a substantive reply within the statutory 15 working days to complaints from customers who had fallen victim to online fraud (November to December 2023 and April to at least August 2024). Because bunq fully or largely compensated those affected without being legally obliged to, the AFM lowered the base amount from 500,000 to 200,000 EUR; the simplified settlement brought a further 15% reduction.

What organisations can take from it

Complaint processes for payment services need deadline monitoring, especially for fraud victims with large losses.

Relevance to training and awareness

Timely handling of complaints in payment services

Authority / court
Autoriteit Financiële Markten (AFM)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 43a Abs. 1 i. V. m. Abs. 2 Besluit Gedragstoezicht financiële ondernemingen Wft (BGfo), Umsetzung von Art. 101 PSD2
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Voluntary full or largely full compensation of the customers concerned; simplified settlement (−15%).
Published
8 Jun 2026

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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29 May 2026 mBank S.A.mBank: PLN 14.9m for failings in treasury business and compliance PolandOrganisational requirements €3.52m

The KNF imposed four fines totalling PLN 14,900,000 on mBank: PLN 0.4m and 6m because staff negotiated client transactions with unauthorised third parties and passed client information to them, PLN 5m for not treating currency hedging transactions as financial instruments and PLN 3.5m for ineffective internal control and compliance functions. Following a request for reconsideration, the KNF upheld the decision on 28 August 2026; it is not final.

What organisations can take from it

Staff may negotiate client transactions only with persons whose authority has been verified, and the compliance function must monitor this.

Relevance to training and awareness

Verifying authority and confidentiality in client dealings

Authority / court
Komisja Nadzoru Finansowego (KNF)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
§ 8 Abs. 1 i. V. m. § 26 Nr. 1 Verordnung des Finanzministers vom 24.09.2012; Art. 83b Abs. 3 und 6, Art. 83c Abs. 1 ustawa o obrocie instrumentami finansowymi; Art. 9c Abs. 1 Nr. 4 Prawo bankowe; Art. 21 und 22 Delegierte Verordnung (EU) 2017/565
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 14,900,000 PLN, converted at the ECB reference rate of 29 May 2026.

Sources

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

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26 May 2026 TGI AGLiechtenstein: FMA halts TGI AG products over deposit-taking without a licence LiechtensteinCapital markets and financial supervision Order

The Finanzmarktaufsicht Liechtenstein (FMA, Financial Market Authority) ordered by decree of 26 May 2026 that TGI AG in Vaduz immediately stop distributing and publicly offering its products “Customer Basic 2 %”, “Sales Premium” and “Sofortrabatt”, because it was thereby conducting deposit-taking business without a licence, and that it no longer hold the customer funds received in this way within four months. In a partial decision of 12 August 2026 the FMA's appeals commission granted suspensive effect only for the order concerning the holding of the funds; the other measures remain in force and the proceedings are not final.

What organisations can take from it

Business models in which customer money is taken in and later repaid must be checked for a licensing requirement of the financial regulator before launch.

Relevance to training and awareness

Licensing requirement when accepting customer funds (deposit-taking)

Authority / court
Finanzmarktaufsicht Liechtenstein (FMA)
Area of law
Capital markets and financial supervision
Action
Order
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
28 May 2026

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Recognising unusual transactions and filing suspicious transaction reports without delay

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

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

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

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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
Sources

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

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18 May 2026 Havenport Investments Pte LtdMAS: composition fine for Havenport Investments SingaporeOrganisational requirements €26,855

The fund manager Havenport Investments Pte Ltd lacked an adequate framework for managing the risks of the assets under its management, breached its base capital requirement without reporting this to the Monetary Authority of Singapore (MAS, Singapore's central bank and financial regulator), and violated conditions of its Capital Markets Services Licence requiring prior approval for a new product and personalised advice from independent financial advisers for retail investors before onboarding. MAS allegedly imposed a composition fine of SGD 40,000; the company has ceased its retail fund management business and has not been allowed to manage retail investors' money since 18 July 2024. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Licence conditions and capital requirements belong in ongoing compliance monitoring by senior management; any shortfall must be reported immediately.

Relevance to training and awareness

Senior management duties regarding licence conditions, capital requirements and reporting to the regulator

Authority / court
Monetary Authority of Singapore (MAS)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Securities and Futures Act (SFA) und zugehörige Regulations; Auflagen der Capital Markets Services Licence
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
18 May 2026

Original amount 40,000 SGD, converted at the ECB reference rate of 18 May 2026.

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

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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

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

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13 May 2026 Pareto Securities AbPareto Securities: EUR 115,000 for gaps and duplicate filings in transaction reporting FinlandDisclosure and reporting obligations €115,000

The Finanssivalvonta (FIN-FSA, Finnish Financial Supervisory Authority) imposed a penalty payment of 115,000 EUR on Pareto Securities Ab. The firm had submitted no transaction reports at all on 71 days in 2024 and 20 days in 2025, and between June 2023 and May 2025 it reported 13 transactions an unusually high number of times, most of them more than 300 times. The admission of the failings reduced the amount.

What organisations can take from it

Automated reporting pipelines need controls that detect outages and duplicates immediately.

Relevance to training and awareness

Monitoring automated reporting pipelines

Authority / court
Finanssivalvonta (FIN-FSA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 26 Abs. 1 UAbs. 1 MiFIR (VO (EU) Nr. 600/2014); Sijoituspalvelulaki 15 luku 2 § 7 mom. 5 kohta; FivaL 40 §, 41 §
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Admission of the failings and cooperation with the supervisor.
Published
13 May 2026

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money laundering monitoring of foreign exchange with crypto intermediaries

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer due diligence and transaction monitoring for high-risk customers

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

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

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

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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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1 May 2026 Swiss Fund Management AG in Liquidation; BZ Berater Zentrum AGFINMA revokes Swiss Fund Management's licence and confiscates BZ commissions SwitzerlandOrganisational requirements Order

Swiss Fund Management AG in liquidation and BZ Berater Zentrum AG, which held around 2,000 asset management mandates, channelled investor money of around CHF 200 million, directly or via funds, into illiquid bonds of interlinked issuers that financed real estate projects of related companies, without adequately informing investors about the conflicts of interest and without adequate suitability and appropriateness checks under FIDLEG (Swiss Financial Services Act). By ruling of 1 May 2026 the Eidgenössische Finanzmarktaufsicht (FINMA, Swiss Financial Market Supervisory Authority) revoked SFM's licence as a manager of collective assets, rejected BZ's application for a licence as an asset manager and confiscated placement commissions of more than CHF 3 million from BZ. The ruling is final.

What organisations can take from it

Anyone steering client money into products of related companies must disclose the conflicts of interest and document a suitability check for each client.

Relevance to training and awareness

Conflicts of interest and suitability checks in asset management

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Verhaltensregeln nach dem Finanzdienstleistungsgesetz (FIDLEG): Interessenkonflikte, Eignungs- und Angemessenheitsprüfung
Action
Order
Status of proceedings
final
Sector
Financial services and insurance
Published
29 Jun 2026

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

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30 Apr 2026 Deutsche Bank AG London BranchOFSI: GBP 165,000 settlement penalty for Deutsche Bank AG London Branch over payments to an app developer United KingdomBreaches of sanctions and embargoes €190,476

On 30 April 2026 OFSI imposed a monetary penalty of GBP 165,000 on the London branch of Deutsche Bank AG by way of settlement. According to OFSI's findings, in June and July 2022 the branch processed two payments totalling GBP 635,618.75 for a customer to a Russian app developer owned by a designated entity. According to OFSI, its screening provider's list did not contain ownership information on the designated entity, so the beneficiary was not identified. The bank had voluntarily disclosed the payments on 20 September 2022. After a notice of intent of 12 September 2025, which OFSI upheld on 2 December 2025, the bank requested a ministerial review on 23 January 2026; the proceedings ended in settlement. The publication does not state the amount originally proposed. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Imposition of Monetary Penalty – Deutsche Bank AG London Branch (“DBLB”)", 19 May 2026, https://www.gov.uk/government/publications/imposition-of-monetary-penalty-deutsche-bank-ag-london-branch-dblb. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

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, reg. 12; Geldbuße nach s. 146 Policing and Crime Act 2017
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
19 May 2026

Original amount 165,000 GBP, converted at the ECB reference rate of 30 Apr 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · 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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27 Apr 2026 Compensa Towarzystwo Ubezpieczeń S.A. Vienna Insurance GroupCompensa: PLN 8.5m for inadequate motor third-party liability premiums PolandOrganisational requirements €2m

The KNF fined the insurer Compensa PLN 8,500,000 because, in motor third-party liability insurance (class 10) in 2022 to 2024, it set premiums that were insufficient to cover all obligations under the contracts and the costs of its insurance business. The decision is not final.

What organisations can take from it

Insurers must price premiums so that they cover at least all contractual obligations and operating costs, and review this regularly.

Relevance to training and awareness

Adequate premium pricing in insurance

Authority / court
Komisja Nadzoru Finansowego (KNF)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 33 Abs. 2 ustawa z dnia 11 września 2015 r. o działalności ubezpieczeniowej i reasekuracyjnej
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 8,500,000 PLN, converted at the ECB reference rate of 27 Apr 2026.

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

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22 Apr 2026 Keytrade Bank (belgische Zweigniederlassung der Arkea Direct Bank SA)Keytrade Bank: €250,000 for faulty appropriateness warnings in online trading BelgiumOrganisational requirements €250,000

Because of an IT problem, Keytrade Bank displayed the same warning for every order from 27 December 2023 to 13 March 2024, regardless of the complexity of the instrument and the client's known level of knowledge. In the view of the FSMA (Belgian Financial Services and Markets Authority), the bank thereby breached the rules on clear client information and on the appropriateness assessment, including for 81,416 transactions in non-complex instruments, 1,081 transactions in complex instruments without asking for knowledge and experience and 4,542 transactions where the required warning of inappropriateness was missing. The bank refunded losses of affected clients and pays 250,000 EUR under the settlement.

What organisations can take from it

Mandatory warnings in online brokerage must differentiate by product and client profile; changes to this logic need testing and ongoing monitoring.

Authority / court
Autorité des services et marchés financiers / Autoriteit voor Financiële Diensten en Markten (FSMA) – Comité de direction (règlement transactionnel)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 27bis § 1 und Art. 27ter §§ 3 und 5 Gesetz vom 2. August 2002; Art. 71 § 3 Gesetz vom 2. August 2002
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The bank sold affected complex positions, refunded losses and informed the clients.

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

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21 Apr 2026 Unternehmen (Anrufe zur Schadensregulierung), UK (anonymisiert)ICO: enforcement notice against a UK company over claims management calls without consent United KingdomMarketing and consent Order

The ICO issued an enforcement notice to a UK company. The ICO found that the company had instigated calls about claims management services without the consent of the people called. Under regulation 21A of PECR such calls are only permitted with prior consent; the ICO also found a breach of regulation 24. The notice is an enforcement notice and does not impose a fine.

Authority / court
Information Commissioner's Office (ICO)
Area of law
Data protection · Marketing and consent
Legal basis
Regulations 21A und 24 PECR; section 40 DPA 1998
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance

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

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20 Apr 2026 flatexDEGIRO SEBaFin fines flatexDEGIRO €1m for late ad hoc disclosure of special audit findings GermanyDisclosure and reporting obligations €1m

On 20 April 2026 BaFin (German Federal Financial Supervisory Authority) imposed a fine of 1,000,000 EUR on flatexDEGIRO SE. At the end of 2022, the company had not published the results of a special audit under § 44 KWG (German Banking Act) at flatexDEGIRO Bank AG, in which BaFin had identified deficiencies in business organisation, without delay as an ad hoc announcement, but only later as a press release. The fine is final.

What organisations can take from it

Supervisory findings can also be inside information; a press release does not replace an ad hoc announcement.

Relevance to training and awareness

Assessing supervisory audit findings as potential inside information

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 17 Abs. 1 UAbs. 1 MAR (Verordnung (EU) Nr. 596/2014)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
30 Apr 2026

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

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20 Apr 2026 Arrowstreet Capital, Limited PartnershipAFM: €297,000 fine for Arrowstreet Capital over incorrect short position reports NetherlandsDisclosure and reporting obligations €297,000

On 20 April 2026 the Autoriteit Financiële Markten (AFM, Dutch Authority for the Financial Markets) fined the US asset manager Arrowstreet Capital, Limited Partnership 297,000 EUR because, between July 2020 and November 2024, an error in its calculation method led it to report its net short positions in Just Eat Takeaway.com and Galapagos to the AFM too low on 101 occasions, 85 of which also breached the public disclosure obligation. Because the firm reported the error itself, corrected it quickly, cooperated fully and took measures against recurrence, the AFM reduced the base amount by 30%; the simplified settlement brought a further 15% reduction, and the matter is closed.

What organisations can take from it

Calculation methods used for reporting obligations should be validated regularly; self-reporting after discovering an error noticeably lowers the fine.

Relevance to training and awareness

Correct calculation and reporting of net short positions

Authority / court
Autoriteit Financiële Markten (AFM)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 5 Abs. 1 und Art. 6 Abs. 1 Verordnung (EU) Nr. 236/2012 (Leerverkaufsverordnung, SSR)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Self-reporting, prompt correction, full cooperation and measures against recurrence (−30% on the base amount); simplified settlement (−15%).
Published
22 Apr 2026

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

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20 Apr 2026 Sapia Partners LLPFCA: Public censure for Sapia Partners over lack of segregation for client money United KingdomOrganisational requirements Reprimand or warning

The FCA publicly censured Sapia Partners LLP. Sapia was responsible for client money accounts operated in connection with its appointed representative, a wealth manager, but the FCA found that from 2014 to 2020 it did not ensure effective segregation between those making payments and those reconciling the accounts. About £150 million was deposited into the accounts in that period, exposing clients to a risk of loss. Sapia agreed to a voluntary payment of £19,637,950 to that representative's clients; for this reason the FCA did not impose a fine, which it said would otherwise have been £7,412,000 (after discount).

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
FCA Principle 10; CASS 7.12.2R bzw. CASS 7.3.2R; section 205 FSMA 2000
Action
Reprimand or warning
Status of proceedings
final
Sector
Financial services and insurance

Checked against the official source on 28 Sep 2026 · Version 2 · 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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9 Apr 2026 Ara 1857 S.p.A.IVASS fines Ara 1857 €900,000 for failing to carry out required remedies ItalyOrganisational requirements €900,000

IVASS (Italian insurance supervisor) imposed a fine of 900,000 EUR on Ara 1857 S.p.A. under Art. 310(1) of the Private Insurance Code (CAP). The company had not adequately implemented the preventive and corrective measures required by the supervisor, so serious shortcomings persisted in corporate governance, remuneration systems, risk management and control, and in the current and forward-looking solvency assessment. According to IVASS sanctions statistics, the company had already received a fine of 380,000 EUR in 2023.

What organisations can take from it

Supervisory requirements are not recommendations: failing to make the required corrections is in itself a breach that attracts a heavy sanction.

Relevance to training and awareness

Implementing supervisory remedial measures

Authority / court
IVASS (Istituto per la Vigilanza sulle Assicurazioni)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 188 Abs. 3-bis lit. d, Art. 30, 30-bis, 30-ter, 30-quater, 30-septies und 310 Abs. 1 D.Lgs. 209/2005 (CAP); IVASS-Verordnung 38/2018
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Published
29 May 2026

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

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8 Apr 2026 The Goldman Sachs Group, Inc.Goldman Sachs Group: SEK 1.5m for late major shareholding notifications SwedenDisclosure and reporting obligations €139,095

Finansinspektionen (FI, Swedish Financial Supervisory Authority) imposed an administrative fine of 1,500,000 SEK on The Goldman Sachs Group, Inc. because six crossings of the 5% threshold for shares and voting rights in Lundin Mining Corporation, Samhällsbyggnadsbolaget i Norden AB and Scandic Hotels Group AB were notified between 1 and 104 trading days late; a further transaction (Lundin Mining, 27 March 2025) was closed without sanction. FI took into account that a professional market participant had committed breaches in several issuers and saw no grounds for waiving the fine.

What organisations can take from it

Group-wide shareholding monitoring must detect crossings of national notification thresholds on the day they occur and report them on time.

Relevance to training and awareness

Major shareholding notifications (flagging) when thresholds are crossed

Authority / court
Finansinspektionen (FI)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
6 kap. 3 a § första stycket 4 lagen (1991:980) om handel med finansiella instrument (Flaggningspflicht)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Published
10 Apr 2026

Original amount 1,500,000 SEK, converted at the ECB reference rate of 8 Apr 2026.

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

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30 Mar 2026 XTB S.A.XTB: PLN 20m for deficient appropriateness checks in CFD sales PolandOrganisational requirements €4.66m

The KNF fined the brokerage XTB PLN 20,000,000 because, between January 2022 and September 2023, it did not properly assess clients' knowledge and experience, did not adequately define the target market for complex instruments such as CFDs, failed to identify possible conflicts of interest arising from the „lista HOT“ distributed to clients and gave clients unreliable information on CFD risks. At XTB's request the KNF reconsidered the case and upheld the decision on 28 August 2026.

What organisations can take from it

Experience with simple products is not enough to classify complex leveraged products such as CFDs as appropriate for a client.

Relevance to training and awareness

Appropriateness assessment and product governance for leveraged products

Authority / court
Komisja Nadzoru Finansowego (KNF)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 34 Abs. 2 lit. a, Art. 48 und Art. 56 Abs. 1 Delegierte Verordnung (EU) 2017/565; § 37 Abs. 5 Nr. 6 i. V. m. § 31 Abs. 7 Verordnung des Finanzministers vom 30.05.2018; Art. 83c Abs. 2 und Abs. 4 Nr. 2 ustawa o obrocie instrumentami finansowymi
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 20,000,000 PLN, converted at the ECB reference rate of 30 Mar 2026.

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

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30 Mar 2026 Peken Global Limited (KuCoin)Peken Global (KuCoin): 500,000 USD and ban on US access without CFTC registration USAOrganisational requirements €435,388

On a complaint by the CFTC, the federal court in New York entered a consent order against the operator of the KuCoin crypto exchange, which is registered in the Turks and Caicos Islands. Peken Global had given US participants direct access to its trading system without being registered with the CFTC as a foreign board of trade; the court permanently prohibited this and imposed a fine of 500,000 USD. Disgorgement was waived because of the cooperation and the forfeiture in the parallel criminal case, in which Peken Global had pleaded guilty to operating an unlicensed money transmitting business. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Anyone giving US participants direct access to a foreign trading platform needs the appropriate CFTC registration or must effectively block such access.

Authority / court
U.S. District Court for the Southern District of New York (auf Klage der CFTC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
CFTC Regulation 48.3 (17 C.F.R. § 48.3); Section 6c Commodity Exchange Act (7 U.S.C. § 13a-1)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Cooperation with the CFTC and in the criminal proceedings; because of the forfeiture ordered there, the CFTC did not seek disgorgement.
Published
30 Mar 2026

Original amount 500,000 USD, converted at the ECB reference rate of 30 Mar 2026.

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

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27 Mar 2026 Oztures Trading Pty Ltd (Binance Australia Derivatives)Binance Australia Derivatives: 10 million AUD for misclassified retail clients AustraliaOrganisational requirements €5.98m

The Federal Court of Australia, on application by the Australian Securities and Investments Commission (ASIC, Australia's corporate, markets and financial services regulator), imposed a penalty of 10 million AUD because, between July 2022 and April 2023, the provider of crypto derivatives wrongly classified 524 retail clients – more than 85% of its Australian client base – as wholesale clients, depriving them of, among other things, a Product Disclosure Statement, a target market determination and a compliant internal dispute resolution system. The causes were deficient onboarding processes – such as a multiple-choice test that could be retaken without limit – and inadequate training and review; the affected clients suffered 8.66 million AUD in trading losses and paid 3.89 million AUD in fees.

What organisations can take from it

Classifications that remove client protections require robust evidence, trained staff and effective oversight – a knowledge test that can be retaken at will is no substitute for a proper assessment.

Relevance to training and awareness

Client classification (retail or wholesale) and verification of evidence during onboarding

Missing or inadequate training played a role in the decision.

Authority / court
Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Corporations Act 2001 (Cth) ss 1012B(3)(a)(i) und (iii), 994B(1) und (2)(a), 912A(1)(a), (b), (f) und (g); Geldbuße nach s 1317G
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Full compensation of affected clients (around 13.1 million AUD) overseen by ASIC, cooperation in the investigation and the proceedings, admission of all contraventions; no previous court findings.
Published
27 Mar 2026

Original amount 10,000,000 AUD, converted at the ECB reference rate of 27 Mar 2026.

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Recognising and reporting grounds for suspicion in crypto exchange

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

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

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

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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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26 Mar 2026 NN Penzijní společnost, a.s.ČNB: CZK 10m fine for NN Penzijní společnost – savers' interest income booked as its own CzechiaOrganisational requirements €408,530

The ČNB (Czech National Bank) fined NN Penzijní společnost 10,000,000 CZK under the supplementary pension savings act. In 2023 the pension company booked interest income totalling 8,060,467.26 CZK earned on savers' money held in collection and payout accounts as its own income instead of allocating it to the participants. In addition, until at least February 2024 it lacked independent ongoing monitoring of investment limits, effective oversight of outsourced activities and adequate procedures for conflicts of interest within the corporate group.

What organisations can take from it

Income generated on client money belongs to the clients; firms that outsource administration need their own independent controls rather than relying on the provider's data.

Relevance to training and awareness

Fiduciary duties towards savers and oversight of outsourced activities

Authority / court
Česká národní banka (ČNB)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
§ 49 lit. a und b, § 50, § 51, § 54 Abs. 1, § 160 Abs. 1 lit. q und u, § 160 Abs. 10 Zákon č. 427/2011 Sb. (ZDPS, Fassung bis 31. 12. 2024)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 10,000,000 CZK, converted at the ECB reference rate of 26 Mar 2026.

Checked against the official source on 28 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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23 Mar 2026 Revolut Group Holdings Ltd, Revolut Bank UAB, Revolut Securities Europe UABAGCM fines Revolut €11.5m over misleading investment, account and IBAN information ItalyMisleading advertising and pricing €11.5m

The AGCM objected to three unfair commercial practices by Revolut: unclear information that investors sometimes acquire only fractional shares, together with misleading "0% commission" advertising; unclear information on account blocks and their aggressive implementation without adequate prior notice or support; and missing information on the requirements and time needed to obtain an Italian IBAN. Fines of 5,000,000 EUR against Revolut Group Holdings Ltd and Revolut Securities Europe UAB, and of 5,000,000 and 1,500,000 EUR against Revolut Group Holdings Ltd and Revolut Bank UAB, each jointly and severally, were imposed, totalling 11,500,000 EUR.

What organisations can take from it

Account blocks need transparent criteria, timely information and a reachable route to resolve them, and "0% commission" must not be advertised where other costs apply.

Relevance to training and awareness

Transparency on investment products, fee advertising and account blocks

Authority / court
Autorità Garante della Concorrenza e del Mercato (AGCM)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 20, 21, 22, 24, 25 Codice del consumo (D.lgs. 206/2005)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
For the IBAN practice, the AGCM took into account measures that Revolut took on its own initiative during the proceedings.
Published
2 Apr 2026

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

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23 Mar 2026 The Bank of London Group Limited und Oplyse Holdings Limited (vormals The Bank of London Group Holdings Limited)PRA: £2m fine on The Bank of London and its parent for misleading it about capital United KingdomDisclosure and reporting obligations €2.31m

The PRA fined The Bank of London Group Limited and its financial holding company Oplyse Holdings Limited 2,000,000 GBP. Between October 2021 and May 2024 they failed to meet their capital requirements for an extended period, repeatedly misled the PRA about their actual capital position – including with fabricated documents – and did not properly manage or report a large exposure arising from a loan by the bank to its parent. It was the PRA's first fine for a lack of integrity and its first action against a financial holding company; a penalty of 12 million GBP would have been appropriate.

What organisations can take from it

Only the true capital position counts with the regulator – embellished or fabricated evidence turns a capital problem into an integrity breach.

Relevance to training and awareness

Truthfulness towards the regulator; no embellished capital evidence

Authority / court
Prudential Regulation Authority (PRA), Bank of England
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
PRA Fundamental Rules 1, 3, 4 und 7; PRA Rulebook: Reporting (CRR) Part Kap. 3 Art. 5 und Art. 7, Large Exposures (CRR) Part Art. 393–395, Notifications 2.3, Related Party Transaction Risk 2.1 und 2.3, Definition of Capital 7A; ss. 206 und 192Y FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Mitigating circumstances
Because serious financial hardship was demonstrated, the PRA reduced the penalty from 12 million GBP to 2 million GBP; the firms settled with the PRA.
Published
24 Mar 2026

Original amount 2,000,000 GBP, converted at the ECB reference rate of 23 Mar 2026.

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

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20 Mar 2026 Conclusive Financial Limited (auch „PCP Refunds“)FCA orders Conclusive to remove misleading adverts for motor finance claims United KingdomMisleading advertising and pricing Order

The FCA directed the claims management company Conclusive Financial Limited, which also trades as “PCP Refunds”, with immediate effect to remove adverts for motor finance compensation claims and to refrain from similar adverts in future. The adverts used, without permission, edited video clips of the founder of a well-known consumer finance website as well as the FCA logo, presented the firm's authorised status as a mark of quality, cited an unsubstantiated average refund of 1,846 GBP and did not adequately explain the fees charged for its “No Win, No Fee” service.

What organisations can take from it

Financial promotions must not borrow trust from celebrities or regulators' logos, nor promise unsubstantiated average amounts.

Relevance to training and awareness

Compliant advertising on social media; no use of celebrities or regulators' logos

Authority / court
Financial Conduct Authority (FCA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
s. 137S FSMA 2000; CMCOB 3.2.1R, 3.2.7R und 3.2.9R
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Published
14 Apr 2026

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

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19 Mar 2026 Mavera ABMavera: SEK 14.3m for exclusivity clauses with insurance medical advisers SwedenAbuse of market power €1.32m

The Konkurrensverket (Swedish Competition Authority) found that Mavera AB abuses its dominant position by applying, since 1 January 2021, exclusivity clauses in contracts with companies providing insurance medical advice that prohibit advising competing businesses. The authority imposed a competition damages fee (konkurrensskadeavgift) of 14,300,000 SEK and ordered the company to stop applying the clauses and to inform its contractual partners within six weeks; the order is backed by a conditional fine (vite) of 30,000,000 SEK. Mavera has appealed to the Patent- och marknadsdomstolen (Patent and Market Court). The decision is not final.

What organisations can take from it

Exclusivity ties imposed by a dominant customer on service providers can keep competitors out of the market and carry high competition law risk.

Relevance to training and awareness

Exclusivity clauses used by dominant companies

Authority / court
Konkurrensverket
Area of law
Competition law · Abuse of market power
Legal basis
2 kap. 7 § konkurrenslagen (2008:579); Art. 102 AEUV; 3 kap. 1 § och 3 kap. 5 § första stycket 1 KL
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
19 Mar 2026

Original amount 14,300,000 SEK, converted at the ECB reference rate of 19 Mar 2026.

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Counterparty checks and customer identification for crypto transfers

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

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

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

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17 Mar 2026 Alecta Tjänstepension ÖmsesidigtAlecta: warning and SEK 50m over risk control in Heimstaden investments SwedenOrganisational requirements €4.67m

Finansinspektionen (FI, Swedish Financial Supervisory Authority) issued the occupational pension provider Alecta a warning and the statutory maximum administrative fine of 50,000,000 SEK. For investments of around 26.5 billion SEK in Heimstaden Bostad AB between October 2019 and August 2023, Alecta had – with the exception of one investment occasion – not sufficiently identified the risk of loss arising from the articles of association and shareholder agreements, nor ensured that it could manage that risk; the assets were therefore not invested in the way that best served the beneficiaries' interests. FI classified the breaches as serious but refrained from revoking the licence in view of the measures taken.

What organisations can take from it

Anyone investing client money must analyse and document the contractual risks (influence, exit, reinvestment obligations) before each tranche.

Relevance to training and awareness

Risk control and prudence in large investments of pension assets

Authority / court
Finansinspektionen (FI)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
6 kap. 20 § försäkringsrörelselagen (2010:2043) in der Fassung vor dem 1.1.2016; 6 kap. 1–3 §§ lagen (2019:742) om tjänstepensionsföretag; 15 kap. 1, 2 och 16 §§ LTF
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Alecta replaced several senior executives, made staffing changes in asset management and strengthened its board; FI therefore considered a warning rather than licence revocation sufficient.
Published
18 Mar 2026

Original amount 50,000,000 SEK, converted at the ECB reference rate of 17 Mar 2026.

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

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17 Mar 2026 TradeStation Securities, Inc.OFAC: USD 1.11 million settlement with TradeStation over securities trading for customers in Iran, Syria and Crimea USABreaches of sanctions and embargoes €963,196

Online broker TradeStation Securities, Inc. of Florida is paying USD 1,110,661 under a settlement with OFAC for 481 apparent violations of multiple sanctions programmes. According to OFAC's findings, following several failures in compliance controls, customers in Iran, Syria and Crimea were able to execute 481 securities trades worth a total of USD 4,442,645 via the mobile app between June 2021 and June 2022. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed and credited significant remedial measures; the base penalty was USD 2,221,322. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "TradeStation Securities, Inc. Settles with OFAC for $1,110,661 Related to Apparent Violations of Multiple Sanctions Regulations", 17 March 2026, https://ofac.treasury.gov/media/935351/download?inline; summarised in our own words.

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
Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204; Syrian Sanctions Regulations, 31 C.F.R. § 542.207; Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. § 589.207 (481 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
17 Mar 2026

Original amount 1,110,661 USD, converted at the ECB reference rate of 17 Mar 2026.

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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13 Mar 2026 Macquarie Securities (Australia) LimitedMacquarie Securities: 35 million AUD for years of misreported short sales AustraliaDisclosure and reporting obligations €21.5m

The Supreme Court of New South Wales, on application by the Australian Securities and Investments Commission (ASIC, Australia's corporate, markets and financial services regulator), imposed a penalty of 35 million AUD on the securities dealer because, between December 2009 and February 2024, inadequate systems, processes and controls led it to misreport at least 73 million short sales to the market operator and to omit required regulatory data from orders. The court also found inadequate risk management and misleading conduct, and ordered a compliance programme involving an independent expert.

What organisations can take from it

Regulatory reporting processes need their own regularly tested controls, and individual errors that come to light should be investigated as a possible sign of wider system weaknesses.

Relevance to training and awareness

Accuracy of regulatory reporting (short sale and order data) and escalation of identified reporting errors

Authority / court
Supreme Court of New South Wales (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Corporations Act 2001 (Cth) ss 798H(1)(b), 912A(1)(h), 1041H(1); ASIC Market Integrity Rules (Securities Markets) 2017; Geldbuße nach s 1317G(1)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
50 to 249
Mitigating circumstances
Early acceptance of the contraventions, sustained cooperation with ASIC and contrition; the errors were reported to ASIC once identified and promptly remediated; no previous court findings of similar conduct.
Liability of senior managers
According to the decision, the errors arose at an operational level; ASIC did not allege any involvement of senior management.
Published
16 Mar 2026

Original amount 35,000,000 AUD, converted at the ECB reference rate of 13 Mar 2026.

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10 Mar 2026 U K Insurance LimitedPRA: £10.625m fine on U K Insurance for an incorrect Solvency II balance sheet United KingdomDisclosure and reporting obligations €12.3m

The PRA fined U K Insurance Limited, the principal insurance company of the Direct Line Group (part of Aviva since July 2025), 10,625,000 GBP. Because of ineffective controls and staffing and capability issues in its finance and actuarial functions, its Solvency II balance sheet was miscalculated in 2023 and 2024, so that the firm overstated its solvency to the PRA and the market; the error went undetected for a considerable time. It was the first case under the PRA's Early Account Scheme.

What organisations can take from it

Regulatory metrics such as the solvency ratio need effective preventive and detective controls and sufficiently qualified staff.

Relevance to training and awareness

Controls, capability and training in finance and actuarial functions

Missing or inadequate training played a role in the decision.

Authority / court
Prudential Regulation Authority (PRA), Bank of England
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
PRA Fundamental Rule 6; Notifications 6.1; Reporting 2.4 und 3.2 (PRA Rulebook); s. 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
negligent
Mitigating circumstances
Participation in the Early Account Scheme with early admissions: 50% discount (otherwise 21.25 million GBP); after discovery management notified the PRA without delay, corrected the published figures and remedied the causes; in the PRA's view the breaches were neither deliberate nor reckless.
Published
11 Mar 2026

Original amount 10,625,000 GBP, converted at the ECB reference rate of 10 Mar 2026.

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

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10 Mar 2026 Barclays PLCBaFin fines Barclays €1.65m over 26 late voting rights notifications GermanyDisclosure and reporting obligations €1.65m

On 10 March 2026 BaFin (German Federal Financial Supervisory Authority) imposed a fine of 1,650,000 EUR on Barclays PLC. Between June 2022 and March 2023 the company had failed in 26 cases to submit voting rights notifications concerning the same issuer on time; the fine punished a breach of the duty of supervision because adequate organisational measures were lacking. The fine is final.

What organisations can take from it

Anyone holding positions in German issuers needs reliable threshold monitoring, or many missed notifications turn into a high fine.

Relevance to training and awareness

Monitoring voting rights thresholds and notifying on time

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
§ 130 Abs. 1 OWiG i. V. m. § 33 Abs. 1 S. 1, § 34 Abs. 1 S. 1, § 38 Abs. 1 S. 1 und § 39 Abs. 1 WpHG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
The fine punished a breach of the duty of supervision under § 130 OWiG (German Administrative Offences Act): the company had not taken adequate organisational measures to prevent the breaches or make them significantly more difficult.
Published
27 Mar 2026

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9 Mar 2026 Werbendes Unternehmen aus dem Sektor Finanz- und Versicherungsprodukte (anonymisiert)BNetzA: €50,000 fine on financial products seller posing as an advice centre on the phone GermanyMarketing and consent €50,000

The Bundesnetzagentur (Federal Network Agency) fined a company marketing financial and insurance products 50,000 EUR for unlawful telephone advertising. The calls were particularly intrusive, callers falsely claimed to be an independent advice centre and presented sales calls as service calls; the company has appealed.

What organisations can take from it

Anyone marketing by phone must not disguise either their own identity or the promotional purpose of the call.

Relevance to training and awareness

Consent and proof of consent for telephone marketing

Authority / court
Bundesnetzagentur (BNetzA)
Area of law
Data protection · Marketing and consent
Legal basis
UWG – Verbot unerlaubter Telefonwerbung gegenüber Verbraucherinnen und Verbrauchern
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance

Checked against the official source on 2 Oct 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.

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

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

What organisations can take from it

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

Relevance to training and awareness

Investigating adverse media and reporting completely and on time

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

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4 Mar 2026 Santander Bank Polska S.A. (heute Erste Bank Polska S.A.)Santander Bank Polska: PLN 21.1m for failings in securities and treasury business PolandOrganisational requirements €4.95m

The KNF imposed eight fines totalling PLN 21,100,000, among other things for cooperating with unauthorised third parties in client transactions (PLN 2m and 4m), transactions with clients outside the target market (PLN 2.5m), missing cost information on currency hedging transactions (PLN 1m), a non-compliant remuneration system (PLN 0.5m), the execution of orders relating to „Oprocentowanie Nie Wyższe Niż“ (PLN 7m), ineffective internal control and compliance functions (PLN 4m) and failure to archive client correspondence (PLN 0.1m). Following a request for reconsideration, the KNF upheld the fines on 28 August 2026; an action before the administrative court is possible.

What organisations can take from it

Banks must verify the authority of persons acting for clients and equip their compliance function so that it actually detects such gaps.

Relevance to training and awareness

An effective compliance function and dealing with client representatives in treasury business

Authority / court
Komisja Nadzoru Finansowego (KNF)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 83b Abs. 3, Art. 83c Abs. 1 und 4, Art. 83e Abs. 1 ustawa o obrocie instrumentami finansowymi; § 8 Abs. 1 i. V. m. § 26 Nr. 1 Verordnung des Finanzministers vom 24.09.2012; Art. 9c Abs. 1 Nr. 4 und Art. 88k Abs. 6a Prawo bankowe
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 21,100,000 PLN, converted at the ECB reference rate of 4 Mar 2026.

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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

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

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

What organisations can take from it

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

Relevance to training and awareness

AML training for existing and new staff

Missing or inadequate training played a role in the decision.

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

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

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

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

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

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

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

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20 Feb 2026 BofA Securities Europe SABofA Securities Europe: €6.2m ECB penalty for misreporting market risk EU levelDisclosure and reporting obligations €6.2m

According to the ECB decision, BofA Securities Europe SA reported risk-weighted assets for market risk that were too low, and hence incorrect capital ratios, for six quarters (31 December 2022 to 31 March 2024), because it used its internal model for sovereign bond options although its permission did not cover them. The ECB classified the breach as intentional and severe and took remedial action into account as mitigating.

What organisations can take from it

Internal models may only be used within the approved scope; extensions must be applied for with the supervisor in advance.

Relevance to training and awareness

Using internal models only within the approved scope

Authority / court
Europäische Zentralbank (EZB), Bankenaufsicht
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 430 Abs. 1 Buchst. a VO (EU) Nr. 575/2013 (CRR); Art. 18 Abs. 1 VO (EU) Nr. 1024/2013
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Mitigating circumstances
Remedial action to prevent future breaches.
Published
27 Mar 2026

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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

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10 Feb 2026 J.P. Morgan SEJ.P. Morgan SE: €12.18m ECB penalty for misreporting risk-weighted assets EU levelDisclosure and reporting obligations €12.2m

The ECB imposed two penalties on J.P. Morgan SE: 10,150,000 EUR because the bank misclassified corporate exposures in 15 quarterly reports (end-2019 to mid-2023) and reported risk-weighted assets for credit risk that were too low, and 2,030,000 EUR because it wrongly excluded transactions from the calculation of credit valuation adjustment (CVA) risk in 21 reporting periods (2019 to 2024). The ECB regarded both as seriously negligent, caused by evident deficiencies in internal processes; as a result, the reported capital ratios were too high.

What organisations can take from it

Classification of exposures for regulatory reporting needs effective controls; otherwise incorrect capital ratios become a sanctions risk.

Relevance to training and awareness

Accuracy of supervisory reporting

Authority / court
Europäische Zentralbank (EZB), Bankenaufsicht
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 430 Abs. 1 Buchst. a VO (EU) Nr. 575/2013 (CRR); Art. 18 Abs. 1 VO (EU) Nr. 1024/2013
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
negligent
Mitigating circumstances
The bank identified and reported the breaches itself, cooperated and took remedial action.
Published
19 Feb 2026

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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.

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9 Feb 2026 FIIG Securities LimitedFIIG Securities: 2.5 million AUD for inadequate cyber security ahead of data theft AustraliaSecurity measures and risk management €1.48m

The Federal Court of Australia, on application by the Australian Securities and Investments Commission (ASIC, Australia's corporate, markets and financial services regulator), imposed a penalty of 2.5 million AUD on the fixed-income specialist because between March 2019 and June 2023 it lacked adequate cyber security measures, resources and risk management systems – among other things, there was no multi-factor authentication for remote access, no regular penetration testing and no mandatory security awareness training. In a 2023 attack around 385 GB of confidential data were stolen and some 18,000 clients were notified; the court also ordered a compliance programme with an independent expert.

What organisations can take from it

For licensed financial services firms, cyber security is part of their licence obligations: basic measures such as MFA, patching, monitoring, training and a tested incident response plan must be funded and actually implemented.

Relevance to training and awareness

Cyber security basics: multi-factor authentication, patch management, security awareness training, tested incident response plan

Missing or inadequate training played a role in the decision.

Authority / court
Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Information security and cyber · Security measures and risk management
Legal basis
Corporations Act 2001 (Cth) s 912A(1)(a), (d) und (h) i. V. m. s 912A(5A)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Full cooperation, admissions and an agreed statement of facts; no previous contraventions; the known financial losses (remediation costs of around 1.5 million AUD) were largely borne by the company itself.
Published
9 Feb 2026

Original amount 2,500,000 AUD, converted at the ECB reference rate of 9 Feb 2026.

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9 Feb 2026 Kylin International (HK) Co., LimitedSFC: HKD 9m fine for Kylin International over fund management failures Hong KongOrganisational requirements €968,909

The SFC publicly reprimanded Kylin International (HK) and fined it HKD 9 million for failures as investment manager or consultant of six sub-funds of a Cayman Islands fund from August 2018. The SFC found that conflicts of interest arising from six loans by the firm or a director to four sub-funds were neither managed nor disclosed, reconciliations, valuations and audits were missing, investors were wrongly told that the suitability requirement did not apply, KYC and suitability controls were inadequate and anti-money laundering records were missing. The firm ceased its regulated activities at the end of 2023; its licence was revoked at its request in January 2025.

What organisations can take from it

Loans from a manager or its senior management to funds under management are a conflict of interest that must be managed and disclosed to investors.

Relevance to training and awareness

Conflicts of interest and investor information in private fund management

Authority / court
Securities and Futures Commission (SFC), Hongkong
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Section 194 Securities and Futures Ordinance (Cap. 571)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Remedial measures after an SFC review in late 2020, cessation of regulated activities and an otherwise clean disciplinary record.
Liability of senior managers
Measures against individuals are not set out here.
Published
9 Feb 2026

Original amount 9,000,000 HKD, converted at the ECB reference rate of 9 Feb 2026.

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3 Feb 2026 Rangecourt SA (vormals Banque Havilland SA)Upper Tribunal: £4m penalty on former Banque Havilland over plan to manipulate the Qatari riyal United KingdomMarket abuse and insider dealing €4.64m

In 2017 staff at the London branch of the Luxembourg private bank Banque Havilland SA (now Rangecourt SA) prepared a paper setting out manipulative trading strategies intended to put pressure on the Qatari riyal and its peg to the US dollar; it was meant for a UAE sovereign wealth fund. On 3 February 2026 the Upper Tribunal upheld the breach of Principle 1 (integrity) but reduced the penalty of 10,000,000 GBP set by the FCA in its Decision Notice of 17 January 2023 to 4,000,000 GBP.

What organisations can take from it

Offering clients strategies that amount to market manipulation breaches a firm's duty of integrity, even if none of it is ever carried out.

Relevance to training and awareness

Integrity: no market manipulation concepts for clients or prospects

Authority / court
Upper Tribunal (Tax and Chancery Chamber) (Verfahren der Financial Conduct Authority (FCA))
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Principle 1 der FCA Principles for Businesses; s. 206 FSMA 2000; Entscheidung nach s. 133 FSMA 2000
Action
Fine
Status of proceedings
reduced
Sector
Financial services and insurance
Culpability
intentional
Mitigating circumstances
According to the findings the paper was not passed on and the strategy was never implemented; the bank itself reported the matter to the Luxembourg supervisor CSSF and to the FCA, cooperated, had it investigated at its own cost of around £2.5m, and the employees involved had left the bank.
Liability of senior managers
Measures against individuals are not set out here.
Published
3 Feb 2026

Original amount 4,000,000 GBP, converted at the ECB reference rate of 3 Feb 2026.

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2 Feb 2026 Ark Capital Management (Dubai) LimitedDFSA: allegedly USD 504,000 on Ark Capital Management over market abuse controls United Arab EmiratesMarket abuse and insider dealing €425,676

The investment firm did not review alerts from its surveillance system adequately or promptly, so at least ten suspicious trading instances were not reported or reported late; it also failed to notify an agreed, potentially staged change in control. After a 30% settlement discount the DFSA allegedly imposed USD 504,000 (otherwise USD 720,000).

What organisations can take from it

A surveillance system only helps if its alerts are reviewed promptly – and a staged acquisition of shares must still be notified.

Relevance to training and awareness

Consistently working through trade surveillance alerts

Authority / court
Dubai Financial Services Authority (DFSA)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 90(2) Regulatory Law 2004 (DIFC); GEN Rules 11.10.12A, 5.3.20(a), 11.8.11(2), 4.2.3, 4.2.10 DFSA Rulebook
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Settlement (30% discount); USD 720,000 without settlement.
Published
6 Feb 2026

Original amount 504,000 USD, converted at the ECB reference rate of 2 Feb 2026.

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2 Feb 2026 Ed Broking (MENA) LimitedDFSA: USD 455,176 on reinsurance broker Ed Broking (MENA) for deceptive conduct United Arab EmiratesCapital markets and financial supervision €384,439

The reinsurance broker gave cedent insurers and reinsurers different premiums for the same placement, misled reinsurers about deductions and brokerage, and misled a client about the brokerage earned on 121 placements, partly using altered documents. In a settlement the DFSA allegedly imposed USD 455,176: USD 175,343 disgorgement (including interest) and a USD 279,833 penalty (USD 575,104 without settlement). The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Undisclosed brokerage and inconsistent premium figures given to the contracting parties amount to deception – an early self-report reduces the consequences.

Relevance to training and awareness

Transparency on brokerage and premiums in insurance distribution

Authority / court
Dubai Financial Services Authority (DFSA)
Area of law
Capital markets and financial supervision
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Self-report to the DFSA, internal investigation and restitution to clients; settlement (reduction from USD 575,104).
Published
2 Feb 2026

Original amount 455,176 USD, converted at the ECB reference rate of 2 Feb 2026.

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

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

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

What organisations can take from it

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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21 Jan 2026 KB Kookmin Bank, Shinhan Bank, Woori Bank, Hana BankFour major banks exchanged loan-to-value ratios: KRW 272bn fine South KoreaCartels and collusion €158.2m

According to the KFTC (Korea Fair Trade Commission, Korea's competition authority), the four banks exchanged their complete loan-to-value (LTV) ratios for mortgage lending over a long period, between 736 and 7,500 individual values per bank, and adjusted their own ratios accordingly; only conduct from December 2021, when the express prohibition of anti-competitive information exchange entered into force, was pursued. The KFTC issued cease-and-desist orders and fines totalling KRW 272,014 million (Kookmin KRW 69,747 million, Shinhan KRW 63,801 million, Woori KRW 51,535 million, Hana KRW 86,931 million), the first application of that provision.

What organisations can take from it

Exchanging individual contract terms with competitors is a stand-alone competition law infringement even without price fixing.

Relevance to training and awareness

Information exchange with competitors

Authority / court
Korea Fair Trade Commission (KFTC)
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 40 Abs. 1 Nr. 9 MRFTA i. V. m. Art. 44 Abs. 2 Nr. 3 Durchführungsverordnung (Monopoly Regulation and Fair Trade Act)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
21 Jan 2026

Original amount 272,014,000,000 KRW, converted at the ECB reference rate of 21 Jan 2026.

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Money laundering risk assessment by employees

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

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

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15 Jan 2026 Allay Claims LtdICO: £120,000 fine for Allay Claims over marketing texts about PPI tax refunds United KingdomMarketing and consent €138,344

The ICO fined Allay Claims Ltd £120,000 and issued an enforcement notice. The ICO found that the company had sent a large volume of unsolicited text messages promoting services to reclaim tax on PPI refunds; the enforcement notice gives the period as 1 February 2023 to 13 February 2024. The ICO found a serious breach of regulation 22 of PECR (electronic marketing without consent).

Authority / court
Information Commissioner's Office (ICO)
Area of law
Data protection · Marketing and consent
Legal basis
Regulation 22 PECR; section 55A DPA 1998
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 120,000 GBP, converted at the ECB reference rate of 15 Jan 2026.

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Money laundering risk management at trust and company service providers

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

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

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8 Jan 2026 HSBC Bank plcPNF: HSBC Bank plc pays €267.53m over dividend arbitrage (tax fraud) FranceOther €267.5m

HSBC Bank plc concluded a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement) with the Parquet national financier (PNF, French national financial prosecutor) concerning intra-group dividend arbitrage trading structures run through its Paris branch between 2014 and 2019, which avoided withholding tax on dividends and may be classified as aggravated tax fraud. The bank pays a public interest fine of 267,531,000 EUR; for 2019 it had already paid 34,464,424 EUR in taxes, interest and penalties. Validated on 8 January 2026.

What organisations can take from it

Intra-group trades around dividend record dates must be reviewed for tax and criminal law risks before they are approved.

Relevance to training and awareness

Tax-driven dividend trades as a criminal liability risk

Authority / court
Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
Area of law
Other
Legal basis
Art. 41-1-2 Code de procédure pénale (fraude fiscale aggravée)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
8 Jan 2026

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8 Jan 2026 Wealthface LimitedADGM: Wealthface gives enforceable undertaking after capital and reporting breaches United Arab EmiratesOrganisational requirements Other

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) accepted an enforceable undertaking from the wealth manager and robo-adviser after its investigation found that between January 2023 and March 2025 the firm held insufficient liquid assets for most of the period and insufficient capital resources at the end of 2023 and 2024, calculated its capital requirement for three quarters of 2024 on an understated expenditure figure, did not prepare its 2023 financial statements under IFRS and filed them late, had no office in ADGM since the end of 2023 and paid supervision fees late. The firm admitted the alleged contraventions and undertook, among other things, to appoint an independent director within 60 days, to close any capital shortfall, to re-establish its head office and registered office in ADGM and to report monthly on its capital and liquid assets for one year. The undertaking contains no financial penalty.

What organisations can take from it

Capital and liquidity requirements must be calculated continuously and on correct input figures, not only at the reporting date.

Relevance to training and awareness

Ongoing monitoring of capital and liquidity

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Section 235 FSMR 2015; PRU Rules 3.2.4(a), 3.7.2, 3.7.4(1); GEN Rules 4.5.1(1), 6.2.2, 6.6.2; FEES Rule 1.2.2
Action
Other
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Cooperation with the investigation; some of the contraventions (capital calculation and resources, IFRS accounts, office in ADGM) were already being remediated.

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

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6 Jan 2026 Saxo Capital Markets HK LimitedSaxo Capital Markets HK: HKD 4m fine over crypto products sold to retail clients Hong KongOrganisational requirements €438,731

Saxo Capital Markets HK was publicly reprimanded and fined 4,000,000 HKD because between November 2018 and November 2022 retail clients, too, could trade on its online trading platform 32 complex virtual asset-related products which under the regulators' circulars were reserved for professional investors (1,446 transactions by 130 retail clients and six professional investors). The firm neither assessed clients' knowledge nor provided sufficient information and warnings; the detection rules adopted from its parent group had not identified the products as crypto-related.

What organisations can take from it

Group-wide product filters do not replace a firm's own local product due diligence, especially for crypto products subject to distribution restrictions.

Relevance to training and awareness

Distribution of complex crypto products via online platforms

Authority / court
Securities and Futures Commission (SFC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
s. 194 SFO (Cap. 571); Code of Conduct; Guidelines on Online Distribution and Advisory Platforms; SFC-Rundschreiben vom 01.11.2018 und HKMA/SFC-Rundschreiben vom 28.01.2022
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Self-report, voluntary compensation of clients, cessation of regulated activities, cooperation and acceptance of the findings, otherwise clean disciplinary record.
Published
6 Jan 2026

Original amount 4,000,000 HKD, converted at the ECB reference rate of 6 Jan 2026.

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19 Dec 2025 Australia and New Zealand Banking Group LimitedANZ: AUD 135m penalty over conduct in a government bond issue and false reporting AustraliaMarket abuse and insider dealing €76.1m

In April 2023, as a bank managing a AUD 14 billion government bond issue for the Australian Office of Financial Management (AOFM), ANZ sold large volumes of bond futures around the time of pricing without informing the AOFM of its outstanding sales, and from 2021 to 2023 reported inflated secondary market turnover in government bonds to it. The Court imposed AUD 135 million: AUD 85 million for the bond issue (including AUD 80 million for unconscionable conduct) and AUD 50 million for the inaccurate turnover reporting, together with a compliance programme at its own cost. In three retail matters a further AUD 115 million was imposed on the same day in a separate judgment.

What organisations can take from it

A bank managing an issue for a client must disclose its own hedging activity and must not report embellished figures to authorities.

Relevance to training and awareness

Transparency and conflicts of interest in proprietary trading around client transactions; accuracy of reports to authorities

Authority / court
Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
ss 12CB(1), 12DB(1)(a) ASIC Act 2001 (Cth); ss 912A(1)(a), (ca), (f), (5A), 912DAA, 1041H(1) Corporations Act 2001 (Cth)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
Constructive engagement with ASIC and admissions at the earliest available opportunity.
Published
19 Dec 2025

Original amount 135,000,000 AUD, converted at the ECB reference rate of 19 Dec 2025.

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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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18 Dec 2025 R M Capital Pty Ltd; The SMSF Club Pty LtdR M Capital and SMSF Club: 925,000 AUD over accepted referral fees AustraliaGifts, hospitality and benefits €521,597

On an application by the Australian Securities and Investments Commission (ASIC), the Federal Court of Australia allegedly imposed civil penalties totalling 925,000 AUD: 575,000 AUD on the licensee R M Capital and 350,000 AUD on its authorised representative The SMSF Club. Between November 2014 and July 2016 SMSF Club accepted referral fees totalling 135,863.65 AUD (excluding GST) on 52 occasions from a property provider that referred clients to it, who then set up self-managed superannuation funds (SMSFs) with its help and used them to buy property from that provider; the court treated this as prohibited conflicted remuneration, and R M Capital, as licensee, had through gross negligence failed to take reasonable steps to prevent it. Both companies must provide ASIC with an independent expert's report on their compliance arrangements within six months; R M Capital lodged an appeal on 15 January 2026. The decision is not final.

What organisations can take from it

Advisers must not accept commissions from product providers that could influence their recommendations – and licensees must actively check for such arrangements by their representatives and provide training on them.

Relevance to training and awareness

Commissions and benefits from product providers to financial advisers

Missing or inadequate training played a role in the decision.

Authority / court
Federal Court of Australia (Verfahren der Australian Securities and Investments Commission, ASIC)
Area of law
Bribery and corruption · Gifts, hospitality and benefits
Legal basis
Corporations Act 2001 (Cth) s 963F, s 963G(1), s 1317G(1E), s 1101B(1)(a)(i)
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Culpability
negligent
Repeat case
no
Mitigating circumstances
For SMSF Club, ASIC and the company submitted as mitigating that it ended the referral arrangement immediately after ASIC raised concerns in 2016, cooperated and agreed to resolve the matter, that these were the first contraventions alleged against it and that no client loss was alleged; the court allegedly approved the jointly proposed penalty.
Published
19 Dec 2025

Original amount 925,000 AUD, converted at the ECB reference rate of 18 Dec 2025.

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17 Dec 2025 CACEIS BankAMF: €3.5m against CACEIS Bank for control failures as depositary of the H2O funds FranceOrganisational requirements €3.5m

As depositary of the H2O funds, CACEIS Bank, a subsidiary of the Crédit Agricole group, had, according to the AMF (Autorité des marchés financiers, French financial markets authority) Enforcement Committee, not sufficiently verified the manager's procedures for monitoring investment ratios and valuing unlisted securities, and had not effectively checked compliance with investment limits (including for debt securities, currency swaps and the issuer limit for bonds). The Committee imposed 3,500,000 EUR and a warning; the allegation concerning total return swaps was rejected. The bank has appealed to the Conseil d'État.

What organisations can take from it

Depositaries must actually verify fund managers' investment and valuation processes rather than rely on the managers' own statements.

Relevance to training and awareness

Oversight duties of depositaries towards fund managers

Authority / court
Autorité des marchés financiers (AMF), Commission des sanctions
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 3, 6 Delegierte Verordnung (EU) 2016/438; Art. L. 214-10-5 Code monétaire et financier; Art. 323-19 Règlement général de l'AMF
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
18 Dec 2025

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

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

What organisations can take from it

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

Relevance to training and awareness

Timely regulatory returns to the supervisor

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer due diligence and customer risk rating

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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16 Dec 2025 Bank Dierickx Leys NVBank Dierickx Leys: €350,000 for inadequate market abuse surveillance BelgiumMarket abuse and insider dealing €350,000

Bank Dierickx Leys, which focuses on asset management and investment advice, did not submit a single suspicious transaction and order report (STOR) between 3 July 2016 and 25 March 2025. In the view of the FSMA (Belgian Financial Services and Markets Authority), its systems did not monitor all relevant orders, relied on undocumented assessments by traders and were insufficiently documented and reviewed, its training did not fully cover the MAR obligations, and the bank could not rely on an external service provider's system without a delegation agreement. Under the settlement the bank pays 350,000 EUR.

What organisations can take from it

Anyone executing client orders needs complete, documented market abuse surveillance with trained staff; relying on third-party systems does not replace it.

Relevance to training and awareness

Detecting and reporting suspicious orders and transactions (STOR) under MAR

Missing or inadequate training played a role in the decision.

Authority / court
Autoriteit voor Financiële Diensten en Markten / Autorité des services et marchés financiers (FSMA) – Directiecomité (minnelijke schikking)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 16 Abs. 2 Verordnung (EU) Nr. 596/2014 (MAR); Delegierte Verordnung (EU) 2016/957; Art. 71 § 3 Gesetz vom 2. August 2002
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Remedial measures in 2024: new MAR policy, new monitoring system and specific market abuse training.

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Business profiles and handling conflicts of interest in the trust business

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Identifying personal accounts used for business purposes

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

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

Sources

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11 Dec 2025 EFG Bank AGSFC: reprimand and HKD 10.85m fine for EFG Bank over deficient product due diligence Hong KongOrganisational requirements €1.19m

The SFC publicly reprimanded EFG Bank AG and fined it HKD 10,850,000 because, between January 2015 and December 2020, the bank failed to take special product features into account in its due diligence on 322 bonds, updated its policies late after the complex product regime took effect and in some cases served customers without the required information and warning statements. In addition, due diligence records were missing for 141 bonds, and the bank did not report the failures to the SFC immediately. The bank will apply an enhanced complaint handling procedure for customers who acquired one of 351 potentially affected products.

What organisations can take from it

Firms distributing complex products must document their product due diligence in full, update policies immediately when rules change and report identified failures to the regulator without delay.

Relevance to training and awareness

Product due diligence and customer information when distributing complex investment products

Authority / court
Securities and Futures Commission (SFC), Hongkong
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Section 196 Securities and Futures Ordinance (Cap. 571); Code of Conduct for Persons Licensed by or Registered with the SFC; Management, Supervision and Internal Control Guidelines
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Remedial measures on product due diligence, cooperation with the HKMA and the SFC, and commitment to an enhanced complaint handling procedure for affected customers.
Published
11 Dec 2025

Original amount 10,850,000 HKD, converted at the ECB reference rate of 11 Dec 2025.

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

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11 Dec 2025 NN Životná poisťovňa, a.s.NBS: EUR 100,000 fine for NN Životná poisťovňa over unit-linked policy failings SlovakiaOrganisational requirements €100,000

The NBS (National Bank of Slovakia) fined the life insurer NN Životná poisťovňa 100,000 EUR. From 2016 to November 2021 the insurer had not drawn up a fund statute forming part of the contract for six of its own unit-linked funds, and when it replaced 13 existing funds with three new funds on 5 November 2021 it did not act towards its customers with the required professional care.

What organisations can take from it

Fund switches in existing insurance contracts require complete contractual documentation and a documented, customer-focused implementation process.

Relevance to training and awareness

Product changes in unit-linked insurance

Authority / court
Národná banka Slovenska (NBS)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
§ 64 Abs. 6, § 70 Abs. 1 lit. a, § 139 Abs. 1 lit. e und Abs. 11 Zákon č. 39/2015 Z. z. (Versicherungsgesetz)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

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

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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 a competing insurance broker 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).

What organisations can take from it

When hiring employees from competitors, make sure they do not bring customer lists or secrets with them.

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
Measures against individuals are not reported here.
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 28 Sep 2026 · Version 2 · 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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer identification (KYC) at crypto exchanges

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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9 Dec 2025 Bank Nagelmackers NVBank Nagelmackers: €60,000 for unapproved fund advertising in interview form BelgiumMisleading advertising and pricing €60,000

In December 2024 Bank Nagelmackers published, as paid partner content in a magazine, an interview about a sub-fund of its SICAV without identifying it as advertising and without first submitting it to the FSMA (Belgian Financial Services and Markets Authority) for approval. References to the prospectus, the key information document and investor rights, the main risks and the costs were missing, and the benefits were highlighted without presenting the risks equally prominently. Under the settlement the bank pays 60,000 EUR.

What organisations can take from it

Paid interviews or partner content about funds are advertising and require labelling, mandatory information and, in Belgium, prior approval by the FSMA.

Relevance to training and awareness

Advertising financial products: labelling paid partner content and mandatory information

Authority / court
Autoriteit voor Financiële Diensten en Markten / Autorité des services et marchés financiers (FSMA) – Directiecomité (minnelijke schikking)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 60 § 3 und Art. 64 Gesetz vom 3. August 2012 über Organismen für gemeinsame Anlagen; Art. 35–43 KE vom 12. November 2012; Art. 4 Verordnung (EU) 2019/1156; Art. 71 § 3 Gesetz vom 2. August 2002
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Online version removed about ten days after publication, approval process tightened with a systematic double check; subscriptions did not increase afterwards.

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

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9 Dec 2025 Banxso (Pty) LtdBanxso: penalties for misuse of client funds South AfricaCapital markets and financial supervision Fine

The investigation found that the financial services provider had, among other things, misused client funds, supplied false or misleading information to clients and the regulator, promised unrealistic returns and not acted in the interests of clients. The amount and the facts have not been confirmed against the primary source.

Relevance to training and awareness

Segregation and protection of client funds; no promises of returns

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Capital markets and financial supervision
Legal basis
Financial Sector Regulation Act 9 of 2017; Financial Advisory and Intermediary Services Act 37 of 2002; General Code of Conduct for Authorised Financial Services Providers and Representatives (2003); Financial Institutions (Protection of Funds) Act 28 of 2001; Determination of Fit and Proper Requirements for FSPs (2017); Financial Markets Act Regulations (2018)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
9 Dec 2025
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Checked against the official source on 4 Oct 2026 · Direct link

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

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

What organisations can take from it

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

Relevance to training and awareness

Detecting suspicious cheque and cash flows at branches

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

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

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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 a Russian oligarch 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.

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

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2 Dec 2025 Drei Versicherungsunternehmen (anonymisiert)Three Luxembourg insurers: EUR 49,000 for distribution via an unregistered company LuxembourgOrganisational requirements €49,000

The Commissariat aux Assurances (CAA, Luxembourg insurance supervisor) imposed administrative fines of EUR 32,000, EUR 14,000 and EUR 3,000 (EUR 49,000 in total) on three insurers authorised in Luxembourg. They had distributed their products in the EEA through a company that, although run by authorised insurance agents, was itself neither authorised nor entered in a distributor register.

What organisations can take from it

Insurers must check that every distributing company is itself authorised and registered – authorised individuals in its management are not enough.

Relevance to training and awareness

Checking the registration of distribution partners

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 303(1) Loi modifiée du 7 décembre 2015 sur le secteur des assurances (LSA), Buchst. a), j) und k); verletzt Art. 286(4) LSA
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
13 Feb 2026

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

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28 Nov 2025 Westpac New Zealand LimitedWestpac NZ: 3.64 million NZD for breaching responsible lending principles New ZealandInformation duties in online retail €1.8m

The bank lacked adequate systems to give borrowers and, in some cases, guarantors the legally required information about their loans, and in some cases did not apply agreed interest rate discounts on home loans; up to 11,398 borrowers and up to 3,012 guarantors were affected. Following a settlement with the Commerce Commission (New Zealand's competition, consumer and credit regulator), the High Court declared breaches of the responsible lending principles (s 9C CCCFA) and imposed an allegedly agreed civil pecuniary penalty of 3.64 million NZD, according to the Commission the highest under the CCCFA so far. Westpac had self-reported the conduct and refunded 2.67 million NZD to those affected.

What organisations can take from it

Lenders must invest in systems and controls that reliably deliver mandatory disclosures and agreed terms; self-reporting does not protect against a high penalty.

Relevance to training and awareness

Mandatory disclosure for loans and applying agreed terms

Missing or inadequate training played a role in the decision.

Authority / court
High Court (Klage: Commerce Commission)
Area of law
Consumer protection and online retail · Information duties in online retail
Legal basis
Credit Contracts and Consumer Finance Act 2003, ss 9C(1), 9C(2)(a)(ii), 9C(2)(a)(iii)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Self-report, admission of the breaches before proceedings were filed and refunds of 2.67 million NZD to those affected.
Published
28 Nov 2025

Original amount 3,640,000 NZD, converted at the ECB reference rate of 28 Nov 2025.

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

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

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

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

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

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

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19 Nov 2025 Exodus Movement, Inc.OFAC: USD 3.1 million settlement with Exodus over customer support for users in Iran USABreaches of sanctions and embargoes €2.68m

US fintech Exodus Movement, Inc. is paying USD 3,103,360 under a settlement with OFAC for 254 apparent violations of the Iran sanctions. According to OFAC's findings, Exodus provided customer support to users in Iran and in some cases helped them access third-party crypto exchanges through its own wallet software. According to OFAC, on twelve occasions staff, despite being aware of the sanctions, advised users to hide their location via VPN in order to circumvent those exchanges' controls; OFAC treated these instances as egregious. The apparent violations were not voluntarily disclosed; the base penalty was USD 4,774,400. Extensive remediation and cooperation were taken into account. Exodus satisfies USD 630,000 of the settlement amount by investing in additional sanctions controls; USD 2,473,360 is payable to the Treasury. OFAC signed the settlement agreement on 19 November 2025 and published it on 16 December 2025. According to the settlement agreement, the settlement does not constitute an admission by Exodus of the apparent violations. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "Exodus Movement, Inc. Settles with OFAC for $3,103,360 for Apparent Violations of Iran-related Sanctions Regulations", 16 December 2025, https://ofac.treasury.gov/media/934831/download?inline; summarised in our own words.

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
Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204 (254 mutmaßliche Verstöße), in 12 Fällen zusätzlich § 560.203 (Umgehung); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
16 Dec 2025

Original amount 3,103,360 USD, converted at the ECB reference rate of 19 Nov 2025.

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

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19 Nov 2025 Genertel S.p.A.IVASS fines Genertel €533,000 for late handling of motor insurance claims ItalyConsumer protection and online retail €533,000

IVASS (Italian insurance supervisor) imposed a fine of 533,000 EUR on Genertel S.p.A. under Art. 310(1) of the Private Insurance Code (CAP). In 198 motor third-party liability claims between 1 September 2023 and 29 February 2024, the insurer failed to meet the statutory deadlines for making a compensation offer to the injured party or giving reasons for rejecting the claim. According to IVASS statistics, this was the largest single fine of 2025.

What organisations can take from it

Statutory claims-handling deadlines apply to every single claim; insurers that miss them in large numbers must expect a heavy fine.

Relevance to training and awareness

Deadlines in claims handling

Authority / court
IVASS (Istituto per la Vigilanza sulle Assicurazioni)
Area of law
Consumer protection and online retail
Legal basis
Art. 141, 148, 149, 150 und 310 Abs. 1 D.Lgs. 209/2005 (CAP); Art. 8 D.P.R. 254/2006
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
31 Dec 2025

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Negative media reports as a trigger for suspicious transaction reports

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

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

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13 Nov 2025 Tung Tai Securities Company LimitedTung Tai Securities: HKD 900,000 fine after fraud via spoofed email instructions Hong KongOrganisational requirements €99,681

Tung Tai Securities was reprimanded and fined 900,000 HKD because between September 2019 and February 2020, acting on instructions from a bogus email address resembling the genuine one, it sold an overseas client's shares and transferred the proceeds of 3,301,740 USD to three overseas bank accounts not designated by the client. Red flags such as transfers rejected by several banks were ignored, and effective controls to protect client assets from theft and fraud were lacking.

What organisations can take from it

Sale and payment instructions received by email must be confirmed through an independent, pre-registered channel, especially for transfers to new beneficiary accounts.

Relevance to training and awareness

Fraud using spoofed email instructions (business email compromise)

Authority / court
Securities and Futures Commission (SFC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
s. 194 SFO (Cap. 571); Code of Conduct GP 2, GP 3, GP 8, paras. 4.3, 11.1(a); Management, Supervision and Internal Control Guidelines Part VII
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Compensation of the client, improved order-handling and execution procedures, independent review of controls, cooperation, otherwise clean disciplinary record.
Published
13 Nov 2025

Original amount 900,000 HKD, converted at the ECB reference rate of 13 Nov 2025.

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

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12 Nov 2025 Euronext Amsterdam N.V.AFM issues direction to Euronext Amsterdam over access barriers for CSDs NetherlandsOrganisational requirements Order

On 12 November 2025 the Autoriteit Financiële Markten (AFM, Dutch Authority for the Financial Markets) issued a direction (aanwijzing) to Euronext Amsterdam N.V. as operator of the regulated markets because, in the AFM’s view, three conditions of its announced new settlement model for market participants wishing to use a central securities depository (CSD) other than Euronext Securities Milan restricted such CSDs’ access to the transaction feeds. Euronext thereby breached the obligation to provide non-discriminatory and transparent access under Art. 53(1) CSDR. Euronext withdrew the conditions and confirmed access for the CSDs concerned; the direction is final.

What organisations can take from it

Trading venues should check new settlement models before announcing them to ensure that central securities depositories keep non-discriminatory access.

Relevance to training and awareness

Non-discriminatory access to market infrastructure

Authority / court
Autoriteit Financiële Markten (AFM)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 53 Abs. 1 Verordnung (EU) Nr. 909/2014 (CSDR); Anweisung nach Art. 1:75 Abs. 1 i. V. m. Art. 1:3a Abs. 1 Wet op het financieel toezicht (Wft)
Action
Order
Status of proceedings
final
Sector
Financial services and insurance
Published
13 May 2026

Checked against the official source on 2 Oct 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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10 Nov 2025 Bank of Scotland PLCOFSI: GBP 160,000 penalty for Bank of Scotland over payments through a designated person's account United KingdomBreaches of sanctions and embargoes €182,274

On 10 November 2025 OFSI imposed a monetary penalty of GBP 160,000 on Bank of Scotland PLC; without the 50 per cent discount for voluntary disclosure it would have been GBP 320,000, according to OFSI. According to OFSI's findings, between 8 and 24 February 2023 the bank processed 24 payments totalling GBP 77,383.39 through the account of a person designated under Russia sanctions, including credits of GBP 76,000. According to OFSI, screening failed to pick up a variant of the name, and a human error occurred during a PEP review on 20 February 2023. The notice of intent of 28 August 2025 had proposed GBP 175,000. The bank did not request a ministerial review. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Imposition of monetary penalty: Bank of Scotland PLC", 26 January 2026, https://www.gov.uk/government/publications/imposition-of-monetary-penalty-bank-of-scotland-plc. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

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, reg. 11, 12; Geldbuße nach s. 146 Policing and Crime Act 2017
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
26 Jan 2026

Original amount 160,000 GBP, converted at the ECB reference rate of 10 Nov 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · 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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31 Oct 2025 いわき信用組合 (Iwaki Credit Cooperative)Iwaki Credit Cooperative: lending halt for new clients after payments to anti-social forces JapanOrganisational requirements Order

Among other things, between 2004 and 2011 the credit cooperative had channelled loans taken out in the names of uninvolved people without their knowledge, and via shell companies, to a distressed large borrower group, thereby circumventing large-exposure limits; it had paid large cash sums to anti-social forces (hanshakai-teki seiryoku), carried out no suspicious-transaction assessments and given false reports and false statements to the supervisor. Besides a comprehensive business improvement order, lending to new clients was suspended from 17 November to 16 December 2025, combined with training of all staff away from day-to-day business and the immediate severing of ties with anti-social forces; it was the second order against the cooperative in 2025.

What organisations can take from it

When management and control functions jointly cover up breaches, only a rebuild of governance helps, and every false statement to the supervisor makes the consequences worse.

Relevance to training and awareness

Resisting demands from anti-social forces and truthful information to the supervisor

Missing or inadequate training played a role in the decision.

Authority / court
Financial Services Agency (FSA, 金融庁)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Act on Financial Businesses by Cooperatives (協同組合による金融事業に関する法律) Art. 6 Abs. 1 i. V. m. Banking Act (銀行法) Art. 26 Abs. 1; Art. 10 Nr. 2 und 3 (falsche Berichte und Aussagen); Act on Prevention of Transfer of Criminal Proceeds (犯罪収益移転防止法)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Liability of senior managers
Measures against individuals are not set out here.
Published
31 Oct 2025

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

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28 Oct 2025 Versicherungs- und Rückversicherungsmakler (anonymisiert)Luxembourg insurance broker: EUR 35,000 for false information to the CAA LuxembourgDisclosure and reporting obligations €35,000

The Commissariat aux Assurances (CAA, Luxembourg insurance supervisor) imposed an administrative fine of EUR 35,000 on a Luxembourg brokerage company. It had repeatedly given the supervisor incomplete or false information on premiums, shareholders and board, failed to notify changes in its shareholding, used an unregistered intermediary, disregarded reporting instructions and did not keep accounting records properly; the confidentiality of client data in its accounting was also not fully ensured.

What organisations can take from it

Information given to the supervisor and changes among shareholders must be reported completely and on time – repeated misreporting counts as obstructing supervision.

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 303(1) Buchst. a), f), h), j) und k) Loi modifiée du 7 décembre 2015 sur le secteur des assurances (LSA)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Significant internal changes, including in management, and measures to restore compliance.
Published
16 Dec 2025

Checked against the official source on 2 Oct 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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24 Oct 2025 Verus Financial Services LimitedFCA strips Verus Financial Services of permissions after deliberate breach of restriction United KingdomOrganisational requirements Order

The FCA removed all regulated activities from the permission of the financial intermediary Verus Financial Services Limited with immediate effect and imposed an asset restriction. By its own admission the firm had repeatedly and deliberately breached a restriction it had voluntarily accepted in September 2023, which prohibited payments above 5,000 GBP without the FCA's consent, had failed to comply with a Financial Ombudsman Service decision of 30 June 2024 in favour of a customer and, in the FCA's view, had not been open and cooperative.

What organisations can take from it

Restrictions voluntarily agreed with the regulator are binding – deliberately breaching them quickly leads to loss of permission.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
ss. 55J(2)(a)(ii) und 55L(3)(a) FSMA 2000; Threshold Condition para. 2E Schedule 6 FSMA; DISP 3.7.12R; Principles 6 und 11 der FCA Principles for Businesses
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
intentional

Checked against the official source on 3 Oct 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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22 Oct 2025 BofA Securities Inc., Nomura International plc, Standard Chartered Bank u. a. (5 Banken)CADE: settlements with five banks in offshore FX cartel totalling BRL 79m BrazilCartels and collusion €12.7m

On 22 October 2025 the CADE Tribunal approved, in a single block, five cease-and-desist settlements (Termos de Compromisso de Cessação, TCC) with banks and allegedly set the following pecuniary contributions: BofA Securities Inc. 33,010,207.04 BRL, Nomura International plc 32,145,917.76 BRL, Standard Chartered Bank 11,544,947.78 BRL, Credit Suisse AG 1,582,051.57 BRL and MUFG Bank 714,782.33 BRL, together 78,997,906.48 BRL. The session minutes do not state the subject of the proceedings; all five banks are, however, among the parties whose conviction the General Superintendence had recommended in April 2025 in the proceedings on the offshore foreign-exchange cartel (according to CADE, collusion on the prices of FX transactions, exchange of sensitive information and disadvantaging other market participants such as brokers). The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

FX traders must not coordinate prices or customers with competitors; chats between banks are a typical cartel risk.

Relevance to training and awareness

Price-fixing and information exchange in foreign-exchange trading

Authority / court
Conselho Administrativo de Defesa Econômica (CADE), Tribunal Administrativo
Area of law
Competition law · Cartels and collusion
Legal basis
Lei nº 12.529/2011 (Termo de Compromisso de Cessação)
Action
Other
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
Measures against individuals are not set out here.
Published
30 Oct 2025

Original amount 78,997,906.48 BRL, converted at the ECB reference rate of 22 Oct 2025.

Checked against the official source on 3 Oct 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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20 Oct 2025 UBS AGUBS: HKD 8m fine for years of misclassifying professional investors Hong KongOrganisational requirements €883,431

UBS AG was publicly reprimanded and fined 8,000,000 HKD in Hong Kong because, from 2009 to July 2022, its automated process for classifying professional investors rested on a misinterpretation of the minimum portfolio requirement for certain joint accounts. From July 2018 to July 2022 alone, 560 joint accounts were misclassified; securities of 23 of these accounts were lent in 9,190 lending transactions without valid authority, and 94 accounts carried out 500 transactions in products reserved for professional investors. In August 2021 the regulator had already fined UBS 9.8 million HKD, among other things for similar failings.

What organisations can take from it

Automated client classifications must be validated against the wording of the rules, especially for special cases such as joint accounts.

Relevance to training and awareness

Correct classification of professional investors and distribution restrictions

Authority / court
Securities and Futures Commission (SFC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
s. 196 SFO (Cap. 571); s. 4 Securities and Futures (Client Securities) Rules; s. 11(3A) Securities and Futures (Contract Notes, Statements of Account and Receipts) Rules; Securities and Futures (Professional Investor) Rules; Code of Conduct
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Repeat case
yes
Mitigating circumstances
Look-back review and remediation after self-reporting, cooperation, commitment to an enhanced complaint handling procedure for potentially misclassified clients.
Published
20 Oct 2025

Original amount 8,000,000 HKD, converted at the ECB reference rate of 20 Oct 2025.

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer identification and mandatory training at foreign exchange dealers

Missing or inadequate training played a role in the decision.

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

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

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

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

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

What organisations can take from it

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

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

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

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

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16 Oct 2025 Experian Nederland B.V.AP: €2.7m fine for Experian Nederland over credit data processed without legal basis NetherlandsData subject rights and transparency €2.7m

For its Credit Check service, offered until the end of 2024, Experian Nederland B.V. processed data on consumers' creditworthiness without being able to rely validly on legitimate interest, and did not inform the individuals concerned sufficiently. In the objection procedure the AP (Autoriteit Persoonsgegevens, Dutch data protection authority) revoked its original fining decision of 6 December 2023 and set a new fine of 2,700,000 EUR; Experian admitted both infringements.

What organisations can take from it

Anyone collecting credit data on people they have never contacted directly must properly substantiate their legitimate interest and actively inform those concerned.

Relevance to training and awareness

Legitimate interest and information duties at credit reference agencies

Authority / court
Autoriteit Persoonsgegevens (AP)
Area of law
Data protection · Data subject rights and transparency
Legal basis
Art. 5 Abs. 1 lit. a i. V. m. Art. 6 Abs. 1 sowie Art. 12 Abs. 1 i. V. m. Art. 14 Abs. 1 und 2 DSGVO (AVG)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
17 Oct 2025

Checked against the official source on 2 Oct 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 Sanlam Collective Investments (RF) (Pty) LtdSanlam Collective Investments: ZAR 10.6m for breaches of anti-money laundering duties South AfricaCustomer due diligence €527,691

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

What organisations can take from it

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

Relevance to training and awareness

Client risk rating and ongoing and enhanced due diligence

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

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

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

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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 BlueCrest Capital Management (UK) LLPFCA: Public censure for BlueCrest over conflicts between internal and external funds United KingdomOrganisational requirements Reprimand or warning

The FCA publicly censured BlueCrest Capital Management (UK) LLP. Between October 2011 and December 2015 BlueCrest managed external funds for investors as well as an internal fund open only to partners and staff. The FCA found that portfolio managers were moved from the external to the internal fund without the resulting conflict of interest being managed adequately, leaving external investors with an inferior service. Instead of a fine, the FCA took into account BlueCrest's agreement to pay USD 101 million in redress to non-US investors.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
FCA Principle 8 (Interessenkonflikte); section 205 FSMA 2000; section 55L(5) FSMA 2000 (Entschädigungsauflage)
Action
Reprimand or warning
Status of proceedings
final
Sector
Financial services and insurance

Checked against the official source on 28 Sep 2026 · Version 2 · 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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9 Oct 2025 Rakuten Europe Bank S.A.Rakuten Europe Bank: EUR 185,000 for outdated transaction monitoring LuxembourgInternal controls €185,000

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Registration requirements for cryptoasset services

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

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

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30 Sep 2025 Bulls Holding Investments Company S.A., RS Investimentos S/ABulls Holding and RS Investimentos: BRL 508.8m for obstructing supervision BrazilBribery and corruption €81.5m

The Controladoria-Geral da União (CGU, Office of the Comptroller General) fined Bulls Holding Investments Company S.A. BRL 387,431,733.02 and RS Investimentos S/A BRL 121,380,000.00 (BRL 508,811,733.02 in total) and ordered extraordinary publication of the decision for each. According to the final report, the companies had submitted to the insurance supervisor SUSEP bids to take over the pension association APLUB, which was under special intervention, backed by inadequate and in part apparently forged documents, thereby interfering with SUSEP's supervisory activity; RS Investimentos was additionally sanctioned for supporting Bulls Holding's acts. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Misleading documents submitted to a supervisory authority count in Brazil as interference with supervision under the Anti-Corruption Law and can trigger very large fines.

Relevance to training and awareness

Truthful submissions to supervisory authorities

Authority / court
Controladoria-Geral da União (CGU)
Area of law
Bribery and corruption
Legal basis
Lei nº 12.846/2013, Art. 5 II und V, Art. 6 I und II, Art. 14
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
2 Oct 2025

Original amount 508,811,733.02 BRL, converted at the ECB reference rate of 30 Sep 2025.

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

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30 Sep 2025 Oldenburgische Landesbank AGBaFin fines Oldenburgische Landesbank €910,000 over securities business failings GermanyOrganisational requirements €910,000

On 30 September 2025 BaFin (German Federal Financial Supervisory Authority) imposed fines of 910,000 EUR on Oldenburgische Landesbank AG. In 2020 and 2021 the bank lacked adequate IT controls to protect its clients' ownership rights where buy and sell orders were placed on the same day, did not in every case transparently show the costs of the individual components of bundled products, and did not ensure that tied agents properly disclosed inducements. The fine is final.

What organisations can take from it

Programmed controls in securities settlement must be carefully tested before they are introduced, or management is liable for the gap.

Relevance to training and awareness

Protecting client holdings and disclosing costs and inducements transparently

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
§ 130 Abs. 1 OWiG i. V. m. § 84 Abs. 4 S. 1 WpHG i. V. m. § 10 Abs. 4 Nr. 5 WpDVerOV; § 63 Abs. 9 S. 1 WpHG; § 70 Abs. 1 S. 1 Nr. 2 WpHG i. V. m. Art. 50 Abs. 2 Delegierte Verordnung (EU) 2017/565
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
13 Oct 2025

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

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30 Sep 2025 Unternehmen der Finanzwirtschaft (anonymisiert)HmbBfDI: €492,000 over opaque automated rejection of credit card applications GermanyData subject rights and transparency €492,000

A financial services company had rejected several customers' credit card applications by automated means without human involvement despite good creditworthiness, and when asked it did not adequately provide the legally required information and access about the decision. The HmbBfDI (Hamburg data protection authority) imposed 492,000 EUR; substantial process improvements and cooperation were given considerable weight in mitigation, and the company accepted the decision.

What organisations can take from it

Anyone who rejects applications by automated means must be able to show the people affected, on request and in understandable terms, why the decision was taken and what logic it followed.

Relevance to training and awareness

Transparency in automated decision-making

Authority / court
Hamburgischer Beauftragter für Datenschutz und Informationsfreiheit (HmbBfDI)
Area of law
Data protection · Data subject rights and transparency
Legal basis
DSGVO – Informations- und Auskunftspflichten bei automatisierten Entscheidungen im Einzelfall
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Substantial improvement of the process for data subject rights in automated decisions; full cooperation with the authority.
Published
30 Sep 2025

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

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

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

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

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22 Sep 2025 ShapeShift AGOFAC: USD 750,000 settlement with ShapeShift over crypto exchanges with users in sanctioned countries USABreaches of sanctions and embargoes €636,618

Crypto exchange ShapeShift AG, incorporated in Switzerland and operated from Denver, Colorado, is paying USD 750,000 under a settlement with OFAC for apparent violations of multiple sanctions programmes. According to OFAC's findings, between December 2016 and October 2018 ShapeShift exchanged digital assets worth USD 12,570,956 with users in Cuba, Iran, Sudan and Syria in 17,183 instances, although IP addresses revealed their location. The company introduced a sanctions compliance programme only after receiving an OFAC subpoena. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 39,515,000. The low settlement amount reflects the fact that ShapeShift has ceased operations and has limited assets. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "ShapeShift AG Settles with OFAC for $750,000 Related to Apparent Violations of Multiple Sanctions Programs", 22 September 2025, https://ofac.treasury.gov/media/934641/download?inline; summarised in our own words.

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
Cuban Assets Control Regulations, 31 C.F.R. § 515.201(b) (39); Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204 (16.839); Sudanese Sanctions Regulations, 31 C.F.R. § 538.205 (33); Syrian Sanctions Regulations, 31 C.F.R. § 542.207 (272); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
22 Sep 2025

Original amount 750,000 USD, converted at the ECB reference rate of 22 Sep 2025.

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

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

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

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

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

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

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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 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.

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
Measures against individuals are not reported here.

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

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17 Sep 2025 Servicios Financieros Carrefour, E.F.C., S.A.AEPD: €1.5m fine for Carrefour's financial arm after attack using stolen credentials SpainData breaches and data security €1.5m

In December 2023 an attacker used credentials leaked elsewhere to retrieve customer data, including partial payment method data, through a service of the financial services provider. The AEPD found a breach of Art. 5(1)(f) GDPR; the sanction of 2,500,000 EUR was reduced by 40% to 1,500,000 EUR because liability was acknowledged and payment made voluntarily.

What organisations can take from it

Services holding financial data must be able to detect and fend off mass retrievals launched with third-party credentials.

Relevance to training and awareness

Credential stuffing and protecting customer accounts

Authority / court
Agencia Española de Protección de Datos (AEPD)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 5 Abs. 1 lit. f DSGVO
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
40% reduction for acknowledgement of liability and voluntary payment (Art. 85 LPACAP).
Published
19 Dec 2025

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

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17 Sep 2025 Shinhan Securities Co. Ltd.Shinhan Securities: 212,500 USD for 127 wash trades in crude oil futures on NYMEX USAMarket abuse and insider dealing €179,522

Between March 2023 and February 2024 a trader at the Korean financial services firm placed near-simultaneous opposing orders for accounts with the same beneficial owner, so that 127 trades in 440 crude oil futures (around 33.5 million USD) offset each other, some of them against orders from traders on other desks of the firm. The CFTC (U.S. Commodity Futures Trading Commission) treated this as prohibited wash sales and non-competitive trades and, in a settlement, imposed a civil monetary penalty of 212,500 USD and a cease-and-desist order; it granted a 20% reduction for excellent cooperation. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Trade surveillance must catch trades in which orders from different accounts or desks of the same firm meet – such self-matches are quickly treated as wash trades.

Relevance to training and awareness

Prohibition of wash trades and self-matching between a firm's own accounts and desks

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Section 4c(a)(1) und (2)(A) Commodity Exchange Act; CFTC Regulation 1.38(a)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Mitigating circumstances
Excellent cooperation with the Division of Enforcement (20% reduction of the penalty); the CFTC also acknowledged the company's representations regarding its remedial measures.
Published
17 Sep 2025

Original amount 212,500 USD, converted at the ECB reference rate of 17 Sep 2025.

Checked against the official source on 3 Oct 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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9 Sep 2025 Flatiron Futures Traders, LLCFlatiron Futures Traders: 200,000 USD for spoofing in E-mini futures USAMarket abuse and insider dealing €170,300

The CFTC imposed a fine of 200,000 USD on the Illinois trading firm. Measures against individuals are not set out here. From May to December 2022, orders were placed for Flatiron in E-mini S&P 500 and E-mini Nasdaq 100 futures on the CME that were intended to be cancelled before execution, so that the genuine orders on the opposite side were filled faster, in larger quantities or at better prices. The spoof orders exceeded the genuine orders in contract volume by a ratio of five to one. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Trading firms are liable for their traders' spoofing; cancellation ratios and one-sided order patterns belong in ongoing surveillance.

Relevance to training and awareness

Recognising and preventing spoofing in proprietary trading

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Section 4c(a)(5)(C) Commodity Exchange Act (7 U.S.C. § 6c(a)(5)(C))
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Liability of senior managers
Measures against individuals are not set out here.
Published
9 Sep 2025

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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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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8 Sep 2025 Instinet Pacific LimitedSFC: HKD 8m fine for Instinet Pacific over unreported cross trades Hong KongDisclosure and reporting obligations €875,254

The SFC publicly reprimanded Instinet Pacific and fined it HKD 8 million because, between December 2012 and March 2018, the broker failed to report 8,817 pairs of cross trades between clients and an affiliated company, worth around HKD 25.9 billion, to the Stock Exchange of Hong Kong as required by Rule 526 of the Exchange Rules. There were neither internal rules on reporting such trades nor any review of the reporting process.

What organisations can take from it

Every reporting obligation towards an exchange or regulator needs written ownership and regular checks that reports are actually being made.

Relevance to training and awareness

Reporting obligations towards the exchange in securities trading

Authority / court
Securities and Futures Commission (SFC), Hongkong
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Section 194 Securities and Futures Ordinance (Cap. 571); Rule 526 Rules of the Exchange (SEHK); General Principles 2 und 7 sowie Paragraph 12.1 Code of Conduct
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The firm ceased the relevant trade flows on its own initiative and cooperated with the SFC.
Published
8 Sep 2025

Original amount 8,000,000 HKD, converted at the ECB reference rate of 8 Sep 2025.

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

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8 Sep 2025 Vanquis Bank LimitedOFSI: breach by Vanquis Bank published instead of a penalty after a delayed account freeze United KingdomBreaches of sanctions and embargoes Other

On 8 September 2025 OFSI published a report on sanctions breaches by Vanquis Bank Limited but did not impose a monetary penalty. According to OFSI's findings, the account of a person designated under counter-terrorism sanctions remained fully usable for eight days after the designation; during that time GBP 200 was withdrawn in cash and a purchase of GBP 8.99 was made. OFSI had given the bank advance notice the day before the designation. According to OFSI, the staff responsible had been redeployed to remediation work, so the internal one-day deadline for the freeze was missed. The bank reported the breach itself, but only 13 days after the designation. Type of measure: Breach published by OFSI instead of a monetary penalty (disclosure under s. 149(3) PACA 2017). The publication does not mention any pending review. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Disclosure notice: 08 September 2025", 8 September 2025, https://www.gov.uk/government/publications/disclosure-notice-08-september-2025. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

Authority / court
HM Treasury, Office of Financial Sanctions Implementation (OFSI)
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
regulations 11 and 12 of the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019; Veröffentlichung nach section 149(3) Policing and Crime Act 2017
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
8 Sep 2025

Checked against the official source on 28 Sep 2026 · Version 3 · 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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4 Sep 2025 UniCredit Bank Czech Republic and Slovakia, a.s.ČNB: CZK 6m fine for UniCredit Bank over wrong exchange rates on card payments CzechiaConsumer protection and online retail €245,379

By way of a penalty order, the ČNB (Czech National Bank) fined UniCredit Bank Czech Republic and Slovakia 6,000,000 CZK for breaching the duty of professional care under the Banking Act. In 2023 and 2024 the bank settled foreign-currency card payments, contrary to its own card terms, at its own exchange rate, which was less favourable to customers, instead of the VISA rate, affecting 75,712 transactions of 9,467 customers and 16,896 transactions of 2,271 customers. Compensation of customers only began some ten to eleven months later.

What organisations can take from it

A customer complaint about incorrect charges is an early warning; failing to fix the system error and compensate for months invites a sanction.

Relevance to training and awareness

Handling customer complaints and fixing system errors promptly

Authority / court
Česká národní banka (ČNB)
Area of law
Consumer protection and online retail
Legal basis
§ 12 Abs. 3, § 36e Abs. 1 lit. o und Abs. 6 lit. c Zákon č. 21/1992 Sb. (Bankengesetz)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 6,000,000 CZK, converted at the ECB reference rate of 4 Sep 2025.

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

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

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

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

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

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

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2 Sep 2025 OTP banka d. d. (vormals NOVA KREDITNA BANKA MARIBOR d. d.)Slovenia: reprimand for OTP banka (formerly NKBM) over its remuneration policy SloveniaOrganisational requirements Reprimand or warning

In misdemeanour proceedings, Banka Slovenije (Bank of Slovenia) issued a reprimand (opomin) to NOVA KREDITNA BANKA MARIBOR d. d. (now OTP banka d. d.) because its remuneration policy exempted staff with variable pay of up to 100,000 EUR gross from statutory requirements of the Banking Act. As a result, in 2022 the bank paid nine identified staff variable remuneration of more than 50,000 up to 86,000 EUR gross without deferring any part of it. The bank has remedied the breach but has applied for judicial review; the decision is not final.

What organisations can take from it

Exemptions in remuneration policies for material risk takers must be checked against supervisory requirements before they are applied.

Authority / court
Banka Slovenije
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 396 Abs. 1 Nr. 19 i. V. m. Art. 190 Zakon o bančništvu (ZBan-3)
Action
Reprimand or warning
Status of proceedings
under appeal
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not reported here.

Checked against the official source on 28 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

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

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

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

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

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

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

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28 Aug 2025 Deutsche Bank AktiengesellschaftDeutsche Bank: HKD 23.8m fine in Hong Kong over fee and disclosure errors Hong KongOrganisational requirements €2.62m

Deutsche Bank AG was publicly reprimanded and fined 23,800,000 HKD in Hong Kong. Clients were overcharged fees of about 5 million USD in management fees on 39 accounts, 10,988 EUR at 92 customers and 493 USD at 32 customers, because agreed discounts were not applied, floating rate debt instruments were wrongly valued and fund prices were not updated. 261 single stock and 1,590 industry research reports lacked disclosure of investment banking relationships. 40 ETFs were given too low a product risk rating. The proceedings stemmed from the bank's self-reports.

What organisations can take from it

Agreed fee discounts, valuation data from external vendors and disclosures in research reports need regular reconciliation so that system errors do not persist for years.

Relevance to training and awareness

Fee billing, valuation data and disclosure in research reports

Authority / court
Securities and Futures Commission (SFC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
s. 196 SFO (Cap. 571); Code of Conduct GP 2, GP 7, paras. 2.1, 12.1, 16.5(d)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Culpability
negligent
Mitigating circumstances
Self-reports, root-cause analysis, remediation and stronger controls, refund of overcharged fees, breaches found by the regulator to be inadvertent and without intent, cooperation and acceptance of the findings.
Published
28 Aug 2025

Original amount 23,800,000 HKD, converted at the ECB reference rate of 28 Aug 2025.

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

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26 Aug 2025 The Hongkong and Shanghai Banking Corporation LimitedSFC: HKD 4.2m fine for HSBC over faulty disclosures in research reports Hong KongDisclosure and reporting obligations €461,939

The SFC publicly reprimanded The Hongkong and Shanghai Banking Corporation (HSBC) and fined it HKD 4.2 million because, between 2013 and 2021, the bank failed to disclose, or disclosed incorrectly, its investment banking relationships with the companies covered in research reports on Hong Kong-listed securities. The cause was deficiencies in recording and mapping data across systems; an estimated more than 4,200 reports were affected. Following a self-report, the HKMA investigated jointly with the SFC.

What organisations can take from it

Mandatory conflict-of-interest disclosures in research reports are only as reliable as the underlying reference data, whose reconciliation across systems must be checked regularly.

Relevance to training and awareness

Disclosure of conflicts of interest in investment research

Authority / court
Securities and Futures Commission (SFC), Hongkong
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Section 196 Securities and Futures Ordinance (Cap. 571); Paragraph 16.5(d), General Principles 2, 3 und 7 sowie Paragraph 12.1 Code of Conduct
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
No evidence of client losses, root-cause review, enhancement of systems and controls, and cooperation with the HKMA and the SFC.
Published
26 Aug 2025

Original amount 4,200,000 HKD, converted at the ECB reference rate of 26 Aug 2025.

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

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25 Aug 2025 FirstRand Bank Ltd (WesBank); Toyota Financial Services South Africa Ltd; Toyota Motor Corporation u. a. (6 Unternehmen)Competition Tribunal: WesBank and Toyota companies allegedly pay ZAR 30m over non-compete clause South AfricaCartels and collusion €1.46m

According to the Competition Commission, a non-compete clause in the 2000 shareholders' agreement of Toyota Financial Services South Africa (TFSSA), in which WesBank holds a one-third stake, obliged the parties not to compete with each other in financing Toyota vehicles; WesBank therefore referred customers' finance requests to TFSSA (market division). In a settlement without admission of liability, the restraint is relaxed so that WesBank may provide finance quotes to retail customers and dealers at their request, and the six parties (FirstRand Bank, its division WesBank, TFSSA, Toyota Motor Corporation, Toyota Financial Services (UK), Toyota South Africa) allegedly pay ZAR 30m jointly or severally. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Non-compete clauses in joint venture shareholders' agreements should be reviewed regularly, as they can deprive customers of a choice between providers.

Relevance to training and awareness

Non-compete clauses in joint ventures and customer freedom of choice

Authority / court
Competition Tribunal of South Africa (auf Antrag der Competition Commission)
Area of law
Competition law · Cartels and collusion
Legal basis
Competition Act 89 of 1998, s. 4(1)(b)(ii); ss. 49D, 58(1)(b)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
Settlement without admission of liability to end protracted proceedings.
Published
25 Aug 2025

Original amount 30,000,000 ZAR, converted at the ECB reference rate of 25 Aug 2025.

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Suspicious activity reports and handling of high-risk transactions

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money laundering and PEP clients

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer due diligence and adverse media screening

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

AML programme, licence boundaries and disclosure to the regulator

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

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

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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.

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

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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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6 Aug 2025 Finanzierungsgesellschaft (anonymisiert)CBUAE fines finance company AED 600,000 for consumer protection breaches United Arab EmiratesConsumer protection and online retail €140,793

The Central Bank of the UAE (CBUAE) fined an unnamed finance company AED 600,000 under Article 137 of the central bank law (Decretal Federal Law No. 14 of 2018). Examinations had found that the company had failed to comply with the central bank's Market Conduct and Consumer Protection Regulations and Standards.

What organisations can take from it

Consumer protection rules in the financial sector are examined and sanctioned in their own right, not only anti-money laundering obligations.

Relevance to training and awareness

Market conduct and consumer protection at finance companies

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Consumer protection and online retail
Legal basis
Art. 137 Decretal Federal Law No. (14) of 2018; CBUAE Market Conduct and Consumer Protection Regulations and Standards
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
6 Aug 2025

Original amount 600,000 AED, converted at the ECB reference rate of 6 Aug 2025.

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

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31 Jul 2025 ZGR Global Pte. Ltd.; Hanshan Money Express Pte. Ltd.CCCS: 5.37 million SGD against two remittance shops for exchanging exchange rates SingaporeCartels and collusion €3.61m

ZGR Global (formerly Zhongguo Remittance) and Hanshan Money Express, two adjacent leading providers of Chinese yuan remittances in People's Park Complex, shared their current and partly non-public remittance rates with each other daily, often several times a day, from at least January 2016 to February 2022, verbally over the counter, on paper slips or by phone. The Competition and Consumer Commission of Singapore (CCCS) found this to infringe s 34 of the Competition Act and on 31 July 2025 imposed penalties totalling 5,365,007 SGD (ZGR Global 2,793,700, Hanshan 2,571,307 SGD). In addition to its cooperation discount, Hanshan received a further 10% discount for its admission under the Fast Track Procedure.

What organisations can take from it

Even routinely sharing current prices with the competitor next door is prohibited coordination; prices must be set independently.

Relevance to training and awareness

No exchange of prices or pricing intentions with competitors

Authority / court
Competition and Consumer Commission of Singapore (CCCS)
Area of law
Competition law · Cartels and collusion
Legal basis
Competition Act 2004, s 34
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Hanshan: discount for cooperation plus a further 10% for its admission under the Fast Track Procedure.
Published
31 Jul 2025

Original amount 5,365,007 SGD, converted at the ECB reference rate of 31 Jul 2025.

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

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

What organisations can take from it

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

Relevance to training and awareness

AML and sanctions compliance at exchange houses

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

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30 Jul 2025 Societe Generale Securities Australia Pty LimitedSociete Generale Securities Australia: 3.88 million AUD for market gatekeeper failures AustraliaMarket abuse and insider dealing €2.18m

The Markets Disciplinary Panel (MDP) of the Australian Securities and Investments Commission (ASIC, Australia's corporate, markets and financial services regulator) allegedly issued an infringement notice for 3,880,100 AUD to the second-largest participant on the ASX 24 futures market because, between May 2023 and February 2024, it allowed 33 orders from two clients in electricity and wheat futures, placed shortly before market close, which it should have suspected were intended to create a false or misleading appearance in the market ('marking the close', Rule 3.1.2(1)(b)(iii) of the Market Integrity Rules). The MDP considered the conduct reckless after repeated contact from ASIC and treated the firm's compliance culture as an aggravating factor; payment is not an admission of liability.

What organisations can take from it

Firms that give clients market access must monitor their orders effectively and respond to regulators' warnings immediately with concrete action.

Relevance to training and awareness

Detecting suspicious client orders (market manipulation, marking the close) in futures trading

Missing or inadequate training played a role in the decision.

Authority / court
Markets Disciplinary Panel (MDP) der Australian Securities and Investments Commission (ASIC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
ASIC Market Integrity Rules (Futures Markets) 2017, Rule 3.1.2(1)(b)(iii); Corporations Act 2001 (Cth) s 798H(1); Infringement Notice nach reg 7.2A.04 Corporations Regulations 2001
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
2 Sep 2025

Original amount 3,880,100 AUD, converted at the ECB reference rate of 30 Jul 2025.

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

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

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

What organisations can take from it

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

Relevance to training and awareness

AML and sanctions compliance in exchange houses

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

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29 Jul 2025 Sigma Broking LimitedFCA: £1.09m fine for Sigma Broking over deficient transaction reports United KingdomDisclosure and reporting obligations €1.26m

The FCA fined Sigma Broking Limited £1,087,300. The FCA found that between December 2018 and December 2023 almost all of the firm's transaction reports were incomplete or inaccurate, affecting 924,584 transactions. The cause was a reporting system set up incorrectly from the start, whose errors were not fixed for years. The fine includes a 30% discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 26 UK MiFIR; FCA Principle 3; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 1,087,300 GBP, converted at the ECB reference rate of 29 Jul 2025.

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

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

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

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

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

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

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

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

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

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

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

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

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

Relevance to training and awareness

Misrepresentation of licensing status and AML obligations

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

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

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24 Jul 2025 Barents Reinsurance S.A., London BranchPRA: £1.785m fine on the London branch of Barents Reinsurance United KingdomOrganisational requirements €2.06m

The PRA fined the London branch of the Luxembourg reinsurer Barents Reinsurance S.A. 1,785,000 GBP – its first fine on a firm operating purely as a reinsurer. Between July 2021 and October 2023 the branch had not prepared adequately for the UK rules applying after Brexit, implemented internal audit recommendations late, lacked proportionate governance and a business continuity plan tailored to its UK business, and submitted regulatory reports late.

What organisations can take from it

Branches of foreign insurers must also adapt governance, continuity planning and regulatory reporting to local supervisory rules as soon as those rules apply.

Authority / court
Prudential Regulation Authority (PRA), Bank of England
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
PRA Fundamental Rule 6; Conditions Governing Business 2.3 und 2.6; Reporting 2.1 und 2.5 (PRA Rulebook); s. 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
negligent
Mitigating circumstances
Early admissions and cooperation (15% reduction) and settlement (30% discount; 2,550,000 GBP without it); substantial remediation costs; in the PRA's view the breaches were neither deliberate nor reckless.
Published
28 Jul 2025

Original amount 1,785,000 GBP, converted at the ECB reference rate of 24 Jul 2025.

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

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

What organisations can take from it

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

Relevance to training and awareness

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

Missing or inadequate training played a role in the decision.

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer due diligence when selling gift and stored value cards

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

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

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15 Jul 2025 Interactive Brokers LLCOFAC: USD 11.8 million settlement with Interactive Brokers over services for customers in sanctioned jurisdictions and blocked persons USABreaches of sanctions and embargoes €10.1m

Online broker Interactive Brokers LLC of Greenwich, Connecticut, is paying USD 11,832,136 under a settlement with OFAC for apparent violations of multiple sanctions programmes. According to OFAC's findings, between July 2016 and January 2024 the company provided brokerage and investment services to persons in Iran, Cuba, Syria and Crimea, processed trades in securities covered by the Chinese Military-Industrial Complex programme, carried out transactions involving blocked persons under several programmes and made prohibited new investment in Russia; 12,367 transactions were involved in total. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed and credited significant remediation and cooperation; the base penalty was USD 60,130,059. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "Interactive Brokers LLC Settles with OFAC for $11,832,136 Related to Apparent Violations of Multiple Sanctions Regulations", 15 July 2025, https://ofac.treasury.gov/media/934501/download?inline; summarised in our own words.

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
E.O. 13685 § 1(a)(iii), E.O. 14024 §§ 1, 4(a), E.O. 14071 § 1(a)(i); 31 C.F.R. § 515.201 (Kuba), §§ 542.201, 542.207 (Syrien), § 560.204 (Iran), § 583.201 (Global Magnitsky), § 586.201 (Chinese Military-Industrial Complex), § 587.201 (Russian Harmful Foreign Activities), § 591.201 (Venezuela); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
15 Jul 2025

Original amount 11,832,136 USD, converted at the ECB reference rate of 15 Jul 2025.

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

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

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

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Implementing supervisory AML instructions in banks

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

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

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

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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.

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9 Jul 2025 Vocalink LimitedBank of England: £11.9m fine on Vocalink for failing to comply with a direction United KingdomOrganisational requirements €13.8m

The Bank of England fined Vocalink Limited, a service provider to systemically important payment systems, 11,900,000 GBP – its first fine on a financial market infrastructure firm. Vocalink had not fully implemented a direction of June 2021 to remedy identified weaknesses in its systems and controls by the extended deadline of 28 February 2022, yet confirmed compliance to the Bank. According to the Bank, the causes were an insufficiently integrated risk management framework for the remediation programme and critical assurance reports that were not passed on to the risk function, internal audit and the board.

What organisations can take from it

Before a firm confirms to its regulator that it has complied with a direction, every critical assurance report must have reached its governing bodies.

Relevance to training and awareness

Escalating negative assurance findings to governing bodies

Authority / court
Bank of England
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
ss. 191 und 196 Banking Act 2009
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Cooperation with early admission (15% reduction) and settlement (a further 30%); 20,000,000 GBP without the reductions; significant investment in remediating the weaknesses.
Published
9 Jul 2025

Original amount 11,900,000 GBP, converted at the ECB reference rate of 9 Jul 2025.

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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.

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9 Jul 2025 RTAX Financial Corp.RTAX Financial: CAD 175,000 administrative penalty for investment fraud and illegal distribution Canada, AlbertaMarket abuse and insider dealing €109,170

An ASC panel had previously found that RTAX illegally distributed securities and, between 2016 and 2019, defrauded investors of at least CAD 462,421: the money was supposed to go into investments in or loans to third parties but was largely used for personal purposes, unrelated debts and payments to other investors. In its sanctions decision the panel ordered an administrative penalty of CAD 175,000; disgorgement of the CAD 462,421 obtained and costs of CAD 81,755 are separate and are not included in the amount shown. RTAX must permanently cease trading in securities. Measures against individuals are not set out here.

What organisations can take from it

Investor funds must be used strictly for their stated purpose, and no capital may be raised without a prospectus or an exemption.

Relevance to training and awareness

Investment fraud and illegal securities distributions

Authority / court
Alberta Securities Commission (ASC), Hearing Panel
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Securities Act (Alberta), RSA 2000, c. S-4, s. 110(1) (Vertrieb ohne Prospekt) und s. 93(1)(b) (Betrug); Sanktionen nach s. 198 (u. a. s. 198(1)(i) Herausgabe), s. 199 (Verwaltungsstrafe) und s. 202 (Kosten)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
14 Jul 2025

Original amount 175,000 CAD, converted at the ECB reference rate of 9 Jul 2025.

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Ongoing monitoring of existing customer relationships

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

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

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

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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. According to the annual accounts filed with the UK companies register for financial year 2026, the company had around 4,591 employees.

What organisations can take from it

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

Relevance to training and awareness

Plausibility checks in customer onboarding

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

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

Sources

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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3 Jul 2025 Sutor Bank GmbHSutor Bank: court cuts fine over conflicts of interest in Riester products to €190,000 GermanyOrganisational requirements €190,000

On 3 July 2025 BaFin (German Federal Financial Supervisory Authority) imposed fines of 702,500 EUR on Sutor Bank GmbH: in 2020 and 2021 the bank had not clearly informed clients, in connection with a possible contract change for Riester pension products, of its own economic interest and thus of conflicts of interest; in 2020 it had not pointed out the associated risks; and in 2021/2022 it had inadequately informed clients about how long telephone recordings are kept. Following the objection, the Amtsgericht Frankfurt am Main (Frankfurt Local Court) set a fine of 190,000 EUR by judgment of 18 August 2026; the judgment is final.

What organisations can take from it

A firm that offers clients a contract change in which it has its own economic interest must clearly disclose that conflict of interest.

Relevance to training and awareness

Disclosing conflicts of interest to clients

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin); Amtsgericht Frankfurt am Main (Einspruchsverfahren)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
§ 63 Abs. 2 S. 1 i. V. m. S. 2 WpHG; § 63 Abs. 6 S. 1, Abs. 13 Nr. 4 WpHG i. V. m. Art. 44 Abs. 2 b) Delegierte Verordnung (EU) 2017/565; § 83 Abs. 5, Abs. 10 S. 1 WpHG i. V. m. Art. 76 Abs. 8 Delegierte Verordnung (EU) 2017/565
Action
Fine
Status of proceedings
reduced
Sector
Financial services and insurance
Published
19 Aug 2025

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

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money laundering in branches of foreign institutions

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer due diligence and complete information on cross-border transfers

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

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

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

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

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

What organisations can take from it

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

AML obligations of exchange houses

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

High-risk clients and transaction monitoring

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

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

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

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17 Jun 2025 Miller Europe SRLMiller Europe: €500,000 for unreported distribution staff after Brexit BelgiumOrganisational requirements €500,000

The Belgian insurance and reinsurance broker Miller Europe SRL failed on 132 occasions between 31 March 2019 and 15 December 2023 to notify the FSMA (Belgian Financial Services and Markets Authority) without delay of changes in the number of its persons in contact with the public, and appointed too few persons responsible for distribution (at least one per ten persons in contact with the public is required); most of the persons concerned were group employees seconded to the UK branch after Brexit. On 15 December 2023, 250 active persons in contact with the public, 96.5%, had not been notified and 24 persons responsible for distribution were missing. Under the settlement Miller Europe pays 500,000 EUR.

What organisations can take from it

After restructurings such as Brexit, the registration of persons authorised to distribute must be continuously reconciled with the actual organisation.

Authority / court
Autorité des services et marchés financiers / Autoriteit voor Financiële Diensten en Markten (FSMA) – Comité de direction (règlement transactionnel)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 264 § 1 und Art. 268 § 1 Gesetz vom 4. April 2014 über die Versicherungen i. V. m. Art. 6 und 8 des Königlichen Erlasses zu dessen Durchführung; Art. 71 § 3 Gesetz vom 2. August 2002
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Cooperation; remedied since February 2024, new control tools and two additional board members.

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12 Jun 2025 GVA Capital Ltd.OFAC: USD 216 million penalty on GVA Capital over managing an investment for a sanctioned oligarch USABreaches of sanctions and embargoes €186.3m

OFAC has imposed the statutory maximum penalty of USD 215,988,868 on San Francisco venture capital firm GVA Capital Ltd. by way of a Penalty Notice. According to OFAC's findings, between April 2018 and May 2021 GVA Capital knowingly managed an investment for a sanctioned Russian oligarch despite knowing of his blocked status, working with a relative who acted as his proxy. The company also failed to comply fully with an OFAC subpoena for 28 months. OFAC treated the violations as egregious and not voluntarily self-disclosed. The Penalty Notice was preceded by Pre-Penalty Notices dated 13 September 2023 and 22 August 2024. The publication does not mention any pending review. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "OFAC Imposes $215,988,868 Penalty on GVA Capital Ltd. for Violating Ukraine/Russia-Related Sanctions and Reporting Obligations", 12 June 2025, https://ofac.treasury.gov/media/934366/download?inline; summarised in our own words.

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. §§ 589.201(a)(3), 589.201(b)(1), 589.213(a); Reporting, Procedures and Penalties Regulations, 31 C.F.R. § 501.602 (28 Verstöße, Subpoena); Penalty Notice nach 31 C.F.R. § 589.703 und den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
12 Jun 2025

Original amount 215,988,868 USD, converted at the ECB reference rate of 12 Jun 2025.

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

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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

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6 Jun 2025 Belfius Banque SA / Belfius Bank NVBelfius: €6.94m ECB penalty for late implementation of internal models EU levelOrganisational requirements €6.94m

Contrary to an ECB decision, Belfius did not implement the new internal models for calculating capital requirements for credit risk by 26 January 2024 and did not submit an audit report validating them, continuing instead to use outdated models from 27 January 2024 to 17 March 2025, although the ECB had reminded it of the obligation. The ECB assessed the misconduct as high and the breach as severe and imposed 6,940,000 EUR; a remedial measure against the underestimation of risk-weighted exposure amounts was taken into account as mitigating.

What organisations can take from it

Implementation deadlines for models set by the supervisor are binding; delays must be remedied early rather than accepted.

Relevance to training and awareness

Timely implementation of supervisory decisions

Authority / court
Europäische Zentralbank (EZB), Bankenaufsicht
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 18 Abs. 7 VO (EU) Nr. 1024/2013 (Verstoß gegen einen EZB-Beschluss zu internen Modellen)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Remedial measure against the underestimation of risk-weighted exposure amounts.
Published
18 Jul 2025

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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

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2 Jun 2025 Alexandria Group OyjAlexandria Group: EUR 1m over investment advice failings via tied agents FinlandOrganisational requirements €1m

The Finanssivalvonta (FIN-FSA, Finnish Financial Supervisory Authority) imposed a joint penalty payment of 1,000,000 EUR on the investment firm Alexandria Group Oyj. In 2021, before giving investment recommendations through its tied agents, the firm had not obtained all required information on clients' knowledge, investment objectives and ability to bear losses, had not fully retained the information collected and had not organised its internal control adequately. Earlier infringements (2017: a penalty payment of 90,000 EUR and a public warning) were taken into account in setting the amount. The decision is not final.

What organisations can take from it

Firms distributing investment advice through tied agents must enforce the suitability assessment technically and document it in full.

Relevance to training and awareness

Suitability assessment and record-keeping in investment advice

Authority / court
Finanssivalvonta (FIN-FSA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Sijoituspalvelulaki 10 luku 4 § und 11 §, 7 luku 2 §; Del. VO (EU) 2017/565 Art. 21, 54, 55, 72; FivaL 40 §, 41 §, 41 b §
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Repeat case
yes
Published
3 Jun 2025

Checked against the official source on 28 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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28 May 2025 ABN AMRO Bank N.V.OM: €14m for ABN AMRO over aiding dividend tax evasion NetherlandsOther €14m

The Openbaar Ministerie (OM, Dutch Public Prosecution Service) imposed a penalty order (strafbeschikking) with a fine of 14 million EUR on ABN AMRO Bank N.V. as an out-of-court settlement. According to investigations by the FIOD (Fiscal Information and Investigation Service), the Dutch subsidiary of a foreign bank had offset a total of 124 million EUR in dividend tax in its corporate income tax returns for 2009 to 2013, although the shares were only parked in the Netherlands briefly around the dividend date; because share and derivative transactions with ABN AMRO or its legal predecessors formed part of this structure, the OM accuses the bank of aiding and abetting from mid-2010 to mid-2013. In setting the amount the OM took into account the gross revenues from the transactions, the bank’s cooperation and the age of the offences.

What organisations can take from it

Banks should check securities and derivative transactions around dividend dates to see whether they enable counterparties to claim unjustified tax credits.

Relevance to training and awareness

Tax risks of securities and derivative transactions around dividend dates

Authority / court
Openbaar Ministerie (OM), Functioneel Parket
Area of law
Other
Legal basis
Beihilfe (medeplichtigheid) zur vorsätzlich unrichtigen Abgabe von Steuererklärungen; Strafbefehl des OM
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
Cooperation with the investigation; offences dating back a long time.
Published
28 May 2025

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

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27 May 2025 AION BANK SAAION Bank: €700,000 settlement for underpaid interest on savings accounts BelgiumOrganisational requirements €700,000

Because of a faulty IT tool, AION Bank did not fully pay basic interest and loyalty premiums to 7,232 holders of regulated savings accounts from 1 December 2019 to 30 June 2024, a total of 550,898.01 EUR, thereby breaching the statutory conditions for regulated savings accounts. The bank had informed the FSMA (Belgian Financial Services and Markets Authority) itself in January 2024 and refunded 530,316.25 EUR; under the settlement it pays 700,000 EUR and undertakes to compensate any further damage free of charge.

What organisations can take from it

After IT migrations, interest and premium calculations for customer products must be checked before errors accumulate over years.

Authority / court
Autorité des services et marchés financiers / Autoriteit voor Financiële Diensten en Markten (FSMA) – Comité de direction (règlement transactionnel)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 28ter § 2 Gesetz vom 2. August 2002 i. V. m. Art. 2, 4°, b) KE/AR zur Durchführung des CIR 92 und Art. 21, 5° CIR 92; Art. 71 § 3 Gesetz vom 2. August 2002
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Self-reporting to the FSMA, cooperation, replacement of the faulty IT tool, strengthened governance and refunds to customers.

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

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27 May 2025 OTP banka d.d.Croatia: 117,070 EUR fine for OTP banka over missing information in credit agreements CroatiaConsumer protection and online retail €117,070

On application by the Hrvatska narodna banka (HNB, Croatian National Bank), the Općinski prekršajni sud u Zagrebu (Zagreb Municipal Misdemeanour Court) convicted OTP banka d.d. of nine misdemeanours under consumer credit, residential mortgage credit, credit institutions and consumer protection law, including because consumer credit agreements concluded between September 2021 and December 2022 lacked information on the total amount payable, on the assumptions used to calculate the annual percentage rate and on the supervisory authority. The bank received fines totalling 117,070 EUR; the judgment has been final since 18 July 2025.

What organisations can take from it

Consumer credit contract templates should be checked regularly against the mandatory statutory information.

Relevance to training and awareness

Mandatory information in consumer credit agreements

Authority / court
Općinski prekršajni sud u Zagrebu (auf Antrag der Hrvatska narodna banka)
Area of law
Consumer protection and online retail
Legal basis
Art. 26, 27 Zakon o potrošačkom kreditiranju; Art. 361.b Zakon o kreditnim institucijama; Art. 41 Zakon o stambenom potrošačkom kreditiranju; Art. 138 Zakon o zaštiti potrošača
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Liability of senior managers
Measures against individuals are not reported here.

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

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23 May 2025 S-Pankki OyjS-Pankki: EUR 7.67m and public warning over faulty banking software FinlandSecurity measures and risk management €7.67m

The Finanssivalvonta (FIN-FSA, Finnish Financial Supervisory Authority) imposed a joint penalty payment of 7,670,000 EUR on S-Pankki Oyj for failings in operational risk management and additionally issued a public warning. A programming error that was live in a bank system from 20 April to 5 August 2022 had not been adequately tested beforehand; the bank lacked a sufficiently secure system and effective incident management and was insufficiently prepared for outsourcing risks. The warning concerns the failure to apply the required strong customer authentication and payments executed without the payers' consent from 6 May to 5 August 2022; earlier penalty payments imposed on the bank by the supervisor (2019 and 2021) increased the amount. The decision is not final.

What organisations can take from it

Changes to authentication and payment processing need documented testing before going live – even when a service provider develops the software.

Relevance to training and awareness

Testing and change management for security-critical banking software

Authority / court
Finanssivalvonta (FIN-FSA)
Area of law
Information security and cyber · Security measures and risk management
Legal basis
Luottolaitostoiminnasta annettu laki 9 luku 16 § (1, 2 und 4 mom.) mit MOK 8/2014; FivaL 40 §, 41 §, 41 b §; öffentliche Verwarnung nach FivaL 39 § wegen Maksupalvelulaki 85 c § 1 mom. und 38 § 1 mom.
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
Measures to prevent recurrence and cooperation with the supervisor in the investigation reduced the amount.
Published
23 May 2025

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

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

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

What organisations can take from it

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

Relevance to training and awareness

AML frameworks at exchange houses

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Suspicious activity reporting for counterfeit goods trading through payment accounts

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

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

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16 May 2025 PostFinance AGEDÖB orders PostFinance to obtain explicit consent for voice recognition SwitzerlandData subject rights and transparency Order

PostFinance AG created voiceprints of its customers for authentication by voice recognition without obtaining their active consent; customers who did not want this had to object themselves. The Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB, Federal Data Protection and Information Commissioner) considered this processing of biometric data disproportionate and, by ruling of 16 May 2025, ordered PostFinance to obtain explicit consent in future and to delete voiceprints for which no such consent exists. PostFinance has appealed to the Federal Administrative Court.

What organisations can take from it

Biometric procedures need an active opt-in from the individuals concerned; a mere right to object is not enough.

Relevance to training and awareness

Biometric authentication and consent (opt-in instead of opt-out)

Authority / court
Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB)
Area of law
Data protection · Data subject rights and transparency
Legal basis
Bundesgesetz über den Datenschutz (DSG): Grundsatz der Verhältnismässigkeit; biometrische Daten als besonders schützenswerte Personendaten, ausdrückliche Einwilligung
Action
Order
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
7 Aug 2025

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

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

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

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

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

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

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

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Risk rating of clients and beneficial owners

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Suspicious activity reporting and source-of-funds checks

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

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

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

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28 Apr 2025 Interactive Brokers Hong Kong LimitedSFC: HKD 4.2m fine for Interactive Brokers HK over securities lending without authority Hong KongOrganisational requirements €476,704

The SFC publicly reprimanded Interactive Brokers Hong Kong and fined it HKD 4.2 million because, between December 2017 and October 2020, the broker lent securities listed on the Hong Kong stock exchange belonging to 7,911 clients on the basis of expired standing authorities. Owing to a programming error, the renewal notices had not been sent. This breached the Securities and Futures (Client Securities) Rules and the Code of Conduct.

What organisations can take from it

Automated processes for client authorities need independent checks that deadlines and renewals are actually met.

Relevance to training and awareness

Handling client securities and expiry of client authorities

Authority / court
Securities and Futures Commission (SFC), Hongkong
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Section 194 Securities and Futures Ordinance (Cap. 571); Sections 7 und 10 Securities and Futures (Client Securities) Rules; General Principles 7 und 8, Paragraphen 11.1(a) und 12.1 Code of Conduct
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Mitigating circumstances
Self-report and remedial action, conduct not deliberate, no evidence of client loss, cooperation and acceptance of the findings.
Published
28 Apr 2025

Original amount 4,200,000 HKD, converted at the ECB reference rate of 28 Apr 2025.

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Enhanced due diligence on politically exposed persons

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Ongoing monitoring and immediate reporting of unusual transactions

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

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

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22 Apr 2025 African Bank LimitedAfrican Bank: ZAR 700,000 for social-media loan advert presented as an 'investment' South AfricaMisleading advertising and pricing €32,753

A social-media campaign by the bank in December 2023 (#KeFestive), featuring a well-known public figure, presented personal loans as an investment; the authority found this factually incorrect and misleading and also identified weaknesses in the approval process for advertising. Of the 700,000 ZAR penalty, 200,000 ZAR was suspended for two years; the bank has paid 500,000 ZAR. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Advertising for credit products – including with well-known personalities – needs a competent, documented approval that describes the nature of the product correctly.

Relevance to training and awareness

Advert approval and influencer marketing for financial products

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Sections 6(1), 6(3)(a), 6(3)(b) und 6(9) Conduct Standard 3 of 2020 (Banks)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation during the investigation and prompt remedial action; 200,000 ZAR suspended for two years, provided the bank complies with the Conduct Standard.
Published
22 Apr 2025

Original amount 700,000 ZAR, converted at the ECB reference rate of 22 Apr 2025.

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

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16 Apr 2025 NetCents Technology Inc.NetCents Technology: CAD 3.34m disgorgement over misleading crypto coin sale Canada, British ColumbiaDisclosure and reporting obligations €2.11m

In 2017 the Vancouver payment processing company sold its own crypto coin to about 500 investors without a prospectus, raising CAD 3,341,040.91; in doing so it referred to an independent non-profit organisation that did not exist, announced sold-out tranches that had not sold out and cited inflated monthly revenue. It also operated an unrecognised exchange for the coin. Under its settlement with the BCSC, NetCents was permanently barred from trading in securities and must pay the proceeds, frozen since 2018, together with interest to the Commission. The amount of CAD 3,341,040.91 is a disgorgement of the proceeds, not an administrative penalty.

What organisations can take from it

Anyone selling crypto tokens to investors must check securities law obligations and may only make verifiable statements in white papers and announcements.

Relevance to training and awareness

Token sales as securities offerings and truthful investor information

Authority / court
British Columbia Securities Commission (BCSC), Executive Director (Vergleich und Anordnung)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Securities Act (British Columbia), RSBC 1996, c. 418, s. 61 (Prospektpflicht), s. 50(1)(d) (Falschangaben), s. 25 (nicht anerkannte Börse); Anordnungen nach s. 161(1)(b), (d) und (g)
Action
Disgorgement of profits
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
The directors and officers at the time have all left the company; the settlement made a hearing unnecessary.
Published
16 Apr 2025

Original amount 3,341,040.91 CAD, converted at the ECB reference rate of 16 Apr 2025.

Checked against the official source on 3 Oct 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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8 Apr 2025 Regen Serviços Fiduciários Ltda.Regen Serviços Fiduciários: BRL 255,000 CVM fine over incorrect liquidity data BrazilOrganisational requirements €39,713

The CVM ordered Regen Serviços Fiduciários Ltda. to pay a fine of BRL 255,000.00 because its internal controls failed and it repeatedly submitted incorrect information to the authority on the liquidity of the investment funds it administered (Art. 19 Instrução CVM 558 until 30 June 2021, thereafter Art. 22 Resolução CVM 21). The company had not submitted a defence; an appeal with suspensive effect to the CRSFN was available against the decision.

What organisations can take from it

Regulatory reports on fund liquidity need their own plausibility checks; repeated errors count as an organisational failure.

Authority / court
Comissão de Valores Mobiliários (CVM)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Instrução CVM 558/2015, Art. 19; Resolução CVM 21/2021, Art. 22
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
8 Apr 2025

Original amount 255,000 BRL, converted at the ECB reference rate of 8 Apr 2025.

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

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7 Apr 2025 Modefinance S.r.l.Modefinance: €420,000 ESMA fine for misleadingly invoking ESMA EU levelCapital markets and financial supervision €420,000

Between September 2018 and October 2021, the Italian credit rating agency Modefinance S.r.l. stated in four publications on its websites that ESMA had 'certified' or 'validated' its MORE rating model, thereby giving the impression of an endorsement by ESMA that did not exist. ESMA regarded this as a negligent breach of Art. 10(6) of the Credit Rating Agencies Regulation and imposed 420,000 EUR and a public notice.

What organisations can take from it

Anyone referring to a supervisory authority in marketing and publications must not imply an endorsement or certification that does not exist.

Relevance to training and awareness

Misleading references to supervisory authorities in corporate communications

Authority / court
Europäische Wertpapier- und Marktaufsichtsbehörde (ESMA)
Area of law
Capital markets and financial supervision
Legal basis
Art. 10 Abs. 6, Art. 24 und Art. 36a VO (EG) Nr. 1060/2009 (Ratingagentur-Verordnung)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Mitigating circumstances
Voluntary measures to prevent recurrence; repeated commission over more than six months was an aggravating factor.
Published
7 Apr 2025

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

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3 Apr 2025 AC Holding Limited (Cayman Islands, Hayvn-Muttergesellschaft)ADGM: 3.6m USD fine for Hayvn parent over payments routed through unregulated accounts United Arab EmiratesCapital markets and financial supervision €3.24m

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the Cayman Islands parent company of the Hayvn group 3,600,000 USD for being knowingly concerned in unauthorised regulated activities of an unregulated ADGM special purpose vehicle and in breaches of permission by its ADGM subsidiary. Around 3,023 transactions for 241 group clients ran through the bank accounts of that vehicle, with deposits of about 507 million USD and payments of about 558 million USD, although the vehicle held no permission and was not subject to the ADGM anti-money laundering rules. The regulator increased the fine by 20%, partly because the parent did not fully disclose its use of the accounts to the regulator and withheld half of the fees owed to the appointed skilled persons.

What organisations can take from it

A parent company is also liable when it knowingly routes client business through unregulated entities in a financial centre.

Relevance to training and awareness

Licensing within a group: no processing through unregulated entities

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Capital markets and financial supervision
Legal basis
Sections 16, 17 und 20 i. V. m. Section 220 sowie Section 232 FSMR 2015
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Cooperation by the parent company and its audit and risk committee from mid-December 2023; the aggravating factors outweighed this.
Liability of senior managers
According to the Final Notice, the use of the accounts was not approved by the board but directed by the then CEO. Measures against individuals are not set out here.

Original amount 3,600,000 USD, converted at the ECB reference rate of 3 Apr 2025.

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

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3 Apr 2025 AC Limited (Hayvn)ADGM: 3m USD fine and permission cancelled for crypto firm AC Limited (Hayvn) United Arab EmiratesOrganisational requirements €2.7m

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the provider of virtual asset trading and custody 3,000,000 USD and cancelled its Financial Services Permission. Between December 2021 and May 2024 it had dealt in virtual assets that were not accepted and exceeded its asset cap of 1 million USD, let client money run through accounts of an unregulated ADGM special purpose vehicle and of its parent company without formal agreements, maintained seven initially undisclosed client relationships without proper risk assessment and due diligence, and gave the regulator false and misleading information about bank accounts, clients and assets. The regulator considered the contraventions deliberate or at least reckless and increased the fine by 20% because of the false information.

What organisations can take from it

False information to the regulator aggravates any sanction, and client money belongs in dedicated, protected client accounts.

Relevance to training and awareness

Candour towards the regulator and protection of client money

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Sections 17(1), 33, 214(4), 221 und 232 FSMR 2015; GEN Rules 2.2.1, 2.2.3, 2.2.9, 2.2.10, 2.2.11, 3.2.1, 3.3.1, 3.3.3, 3.3.7, 3.3.34, 8.1.2(6); COBS Rules 2.2.1, 14.2.1, 17.2.1; AML Rules 7.1.1, 7.1.2, 7.1.3, 8.3.1(1), 8.4.1
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Cooperation from mid-December 2023 and voluntary cessation of trading from 11 December 2023 under an enforceable undertaking; no previous non-compliance of a similar nature. The aggravating factors outweighed these.
Liability of senior managers
Measures against individuals are not set out here.

Original amount 3,000,000 USD, converted at the ECB reference rate of 3 Apr 2025.

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1 Apr 2025 BFF Bank S.p.A.Banca d'Italia fines BFF Bank €1.45m over credit risk and remuneration failings ItalyOrganisational requirements €1.45m

The Banca d'Italia (Bank of Italy) imposed fines totalling 1,450,000 EUR on BFF Bank S.p.A. under Art. 144 of the Consolidated Banking Act (TUB): 1,200,000 EUR for shortcomings in organisation and internal controls relating to credit risk and 250,000 EUR for breaches of the rules on remuneration and incentive policies. The decision followed an inspection from 11 September 2023 to 12 January 2024; the scale of the shortcomings and the corrective measures taken were taken into account.

What organisations can take from it

Remuneration rules and credit risk management are distinct supervisory duties, and the supervisor sanctions failings in each separately and heavily.

Relevance to training and awareness

Credit risk controls and remuneration policy in banks

Authority / court
Banca d'Italia
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 53 Abs. 1 lit. b und d, Art. 67 Abs. 1 lit. b und d sowie Art. 144 Abs. 1 lit. a TUB (D.Lgs. 385/1993); Circolare Banca d'Italia 285/2013
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The bank's corrective measures were taken into account in setting the fine.
Liability of senior managers
Measures against individuals are not reported here.
Published
2 Jul 2025

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money laundering for crypto-assets

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

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

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1 Apr 2025 Banca di Credito Popolare S.c.p.A.Banca d'Italia fines Banca di Credito Popolare €1.05m over risk management failings ItalyOrganisational requirements €1.05m

The Banca d'Italia (Bank of Italy) imposed a fine of 1,050,000 EUR on Banca di Credito Popolare S.c.p.A. under Art. 144 of the Consolidated Banking Act (TUB). The inspection from 25 September 2023 to 2 February 2024 found shortcomings in the governance, management and control of risks that affected the bank's capital position and supervisory reporting; the bank's remedial measures were taken into account.

What organisations can take from it

Weaknesses in risk management feed through to capital figures and supervisory reports and are sanctioned severely by the supervisor.

Relevance to training and awareness

Risk management and supervisory reporting

Authority / court
Banca d'Italia
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 51, 53 Abs. 1 lit. a, b und d sowie Art. 144 TUB (D.Lgs. 385/1993); Circolare Banca d'Italia 285/2013
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The bank's remedial measures were taken into account.
Liability of senior managers
Measures against individuals are not reported here.
Published
2 Jul 2025

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

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1 Apr 2025 BNY Mellon Fund Management (Luxembourg) S.A.BNY Mellon Fund Management (Luxembourg): EUR 207,310 over oversight of branches LuxembourgOrganisational requirements €207,310

The CSSF fined the fund manager EUR 207,310 because it did not adequately oversee the branches it took over in 2019 in the context of Brexit. An inspection in autumn 2021 found, among other things, that most branch employees had no access to the compliance manual until January 2022. The CSSF took into account an earlier sanction of 8 March 2021 for similar organisational failings.

What organisations can take from it

A firm taking over branches must supervise them itself and make its procedures genuinely accessible to branch staff.

Relevance to training and awareness

Staff access to compliance policies and oversight of branches

Authority / court
Commission de Surveillance du Secteur Financier (CSSF)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 148(2)(g) und 148(4)(e) i. V. m. Art. 109(1)(a) Loi modifiée du 17 décembre 2010 (OPC); Règlement CSSF 10-04; Circulaire CSSF 18/698
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
The manager had already taken remedial measures.
Published
20 May 2025

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

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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

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

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26 Mar 2025 Woori Card Co., Ltd.Woori Card: 13.451 billion KRW after a branch used merchant data for card marketing South KoreaMarketing and consent €8.51m

From July 2022 to April 2024, the Incheon sales branch of Woori Card Co., Ltd. looked up data on at least 207,538 owners of card-accepting merchants in the merchant management system, including resident registration numbers, and passed it via chat and e-mail to card recruiters, who used it to market new credit cards; 74,692 of those affected had not consented to marketing. The authority also criticised excessively broad access rights and the company’s failure to intervene despite more than 30 million look-ups and downloads a month, and imposed a penalty surcharge of 13,451,000,000 KRW. It ordered a review of internal controls, training and supervision of staff, minimised access rights and regular log reviews.

What organisations can take from it

Access rights to customer databases must be limited to what is necessary and bulk look-ups monitored automatically – otherwise a sales branch becomes a data source for sales.

Relevance to training and awareness

Purpose limitation and data misuse by employees

Missing or inadequate training played a role in the decision.

Authority / court
Personal Information Protection Commission (PIPC, 개인정보보호위원회)
Area of law
Data protection · Marketing and consent
Legal basis
Personal Information Protection Act (개인정보 보호법) Art. 18(1), Art. 24-2(1), Art. 29; Sanktion nach Art. 64-2(1) Nr. 1
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Reduction of 50% for an ISMS-P certification; increase of 25% because the infringement lasted around one year and nine months.
Liability of senior managers
Measures against individuals are not set out here.
Published
27 Mar 2025

Original amount 13,451,000,000 KRW, converted at the ECB reference rate of 26 Mar 2025.

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

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24 Mar 2025 Tokio Marine & Nichido Fire Insurance, Sompo Japan Insurance, Mitsui Sumitomo Insurance u. a. (4 Unternehmen)Four insurers: orders after customer data were passed on via agencies JapanOrganisational requirements Order

Multi-insurer agencies had forwarded policyholder data to competing insurers, and insurance staff seconded to agencies had sent the agencies’ customer data to their employer without the agencies’ consent; from the agency channel alone, Tokio Marine & Nichido reported 1,004,861, Sompo Japan 799,331, Mitsui Sumitomo 319,915 and Aioi Nissay Dowa 221,144 affected records. The business improvement orders under Art. 132(1) of the Insurance Business Act require a compliance organisation for data protection and unfair competition law, customer data management also at the agencies, stricter rules on secondments, a review by external experts and a fundamental overhaul of the improvement plans submitted after the December 2023 order.

What organisations can take from it

Seconded staff and multi-insurer agencies are data protection risks: customer data may only flow between agency and insurer on a lawful basis.

Relevance to training and awareness

Passing on customer data in sales via agencies

Missing or inadequate training played a role in the decision.

Authority / court
Financial Services Agency (FSA, 金融庁)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Insurance Business Act (保険業法) Art. 132 Abs. 1; Bezug zum APPI (個人情報保護法) und zum Unfair Competition Prevention Act (不正競争防止法)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Repeat case
yes
Published
24 Mar 2025

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

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21 Mar 2025 Hub Capital Inc.FINTRAC: CAD 99,000 penalty on Hub Capital Inc. for 4 violations of anti-money laundering obligations CanadaInternal controls €63,662

According to FINTRAC, Hub Capital Inc. is a securities dealer or wealth management firm based in Woodbridge, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 99,000 on the company on 21 March 2025. According to FINTRAC's findings, made during a compliance examination in 2023, the company committed 4 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the compliance training programme and the prescribed review of the compliance programme. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Hub Capital Inc.", published 12 June 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-06-12-eng; summarised in our own words; not an official version and not a reproduction of the original.

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

Original amount 99,000 CAD, converted at the ECB reference rate of 21 Mar 2025.

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

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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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18 Mar 2025 LGSS Pty Ltd (Trustee des Active Super Fonds)ASIC: 10.5 million AUD against LGSS (Active Super) for greenwashing on exclusion screens AustraliaMisleading environmental and sustainability claims €6.12m

Following proceedings by the Australian Securities and Investments Commission (ASIC, the federal corporate and financial services regulator), the Federal Court of Australia on 18 March 2025 ordered LGSS Pty Ltd, trustee of the Active Super pension fund, to pay 10.5 million AUD and to send a notice of its misconduct to members and publish it on the fund's web pages. The fund had advertised that it excluded investments in, among others, gambling, coal mining and oil tar sands and, after the invasion of Ukraine, Russia, yet held such investments directly or indirectly; the court had found the breaches of the ban on misleading representations in June 2024.

What organisations can take from it

Advertised exclusion criteria must be reflected in all holdings, including indirect ones; deviations must be detected and corrected on an ongoing basis.

Relevance to training and awareness

Exclusion criteria and sustainability promises in fund marketing

Missing or inadequate training played a role in the decision.

Authority / court
Australian Securities and Investments Commission (ASIC) / Federal Court of Australia
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
ASIC Act 2001 (Cth) ss 12DB(1)(a) und 12DF(1); Strafe nach s 12GBB, Veröffentlichungsanordnung nach s 12GLB
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The court accepted some contrition, cooperation with ASIC through attendance at voluntary conferences and compliance improvements (including ESG and consumer law training for the board, executive leadership and staff, and an external review of internal controls), but gave less weight to contrition and cooperation because of how the case was defended; the merger with another fund trustee reduced the weight of specific deterrence.
Liability of senior managers
LGSS accepted in the proceedings that senior management was ultimately responsible for the absence of properly functioning systems to prevent false ESG representations; the proceedings were brought against the company only.
Published
18 Mar 2025

Original amount 10,500,000 AUD, converted at the ECB reference rate of 18 Mar 2025.

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

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18 Mar 2025 NZForex LimitedNZForex: formal warning over 3,182 unreported transactions New ZealandMoney laundering and terrorist financing Reprimand or warning

The company disclosed to the DIA (Department of Internal Affairs, New Zealand's AML/CFT supervisor) that, because of a system error in its prescribed transaction reporting, 3,182 transactions not denominated in New Zealand dollars had not been reported to the Police Financial Intelligence Unit between November 2017 and February 2024. On 18 March 2025 the DIA issued a formal warning under the AML/CFT Act 2009 and, given the prompt voluntary disclosure, refrained from more serious action; NZForex must provide the final report of an independent audit and report on its remediation.

What organisations can take from it

Reporting processes for prescribed transactions need regular reconciliation so that system errors do not go unnoticed for years; early self-reporting can substantially reduce the sanction.

Relevance to training and awareness

Complete reporting of prescribed transactions to the FIU

Authority / court
Department of Internal Affairs (DIA)
Area of law
Money laundering and terrorist financing
Legal basis
Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (Meldung vorgeschriebener Transaktionen)
Action
Reprimand or warning
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Prompt voluntary disclosure, admission of fault, fixing the system error, reporting all outstanding transactions and a voluntary independent audit.
Published
18 Mar 2025

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17 Mar 2025 Qualicorp Consultoria e Corretora de Seguros S.A.Qualicorp: leniency agreement worth BRL 44.5m over payment to a public official BrazilBribery of public officials €7.15m

Qualicorp Consultoria e Corretora de Seguros S.A. acknowledged, in a leniency agreement with the CGU and the AGU, that it had paid an economic advantage to a public official whose action or omission was in the company's interest. It allegedly pays BRL 44,485,434.29 as a fine plus disgorgement: BRL 27,803,396.43 as disgorgement of the advantage obtained and a fine of BRL 16,682,037.86 under Lei 12.846/2013 (40% reduction), both indexed to IPCA up to December 2024. The agreement extends to other companies of the Qualicorp group. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

If management knows of or tolerates payments to officials, the fine rises; without an effective compliance programme there is also no mitigating factor.

Relevance to training and awareness

Payment to a public official to influence official action

Authority / court
Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Lei 12.846/2013, Art. 6 I, Arts. 16 und 17, Art. 19 I; Lei 8.429/1992; Decreto 11.129/2022
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Credit was given for returning the advantage (1%), cooperation (1.5%) and voluntary admission (2%); no compliance programme was taken into account. The fine equals the statutory minimum of the advantage obtained, then reduced by 40%.
Liability of senior managers
Tolerance or knowledge by senior management was applied as an aggravating factor at the maximum rate of 3%.

Original amount 44,485,434.29 BRL, converted at the ECB reference rate of 17 Mar 2025.

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17 Mar 2025 Sparebank 1 ØstlandetSparebank 1 Østlandet: NOK 30m for anti-money laundering failures NorwayInternal controls €2.6m

Finanstilsynet (Norwegian Financial Supervisory Authority) fined Sparebank 1 Østlandet NOK 30,000,000 under the Anti-Money Laundering Act after an inspection in September 2022 revealed fundamental shortcomings in risk assessment, procedures, customer risk classification, customer due diligence and ongoing monitoring, as well as a breach of the tipping-off prohibition; the authority classed the breaches as serious and long-standing. It also found that staff training had been inadequate and ordered the bank to complete due diligence measures for one customer. The bank appealed on 8 May 2025. The decision is not final.

What organisations can take from it

Risk-based anti-money laundering compliance stands or falls with an up-to-date risk assessment and role-specific training tailored to the firm's own procedures.

Relevance to training and awareness

Risk-based anti-money laundering controls and role-specific training

Missing or inadequate training played a role in the decision.

Authority / court
Finanstilsynet
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
§§ 6, 7, 8, 9, 12, 13, 14, 17, 18, 24, 25, 28 und 49 hvitvaskingsloven; § 47 hvitvaskingsloven (Anordnung)
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Culpability
negligent
Published
26 Mar 2025

Original amount 30,000,000 NOK, converted at the ECB reference rate of 17 Mar 2025.

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

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14 Mar 2025 ING Bank N.V., Sucursal en EspañaAEPD: €1.6m fine for ING Spain over social security check when opening accounts SpainData protection €1.6m

ING made opening an account conditional on customers consenting to the retrieval of information on their economic activity from the social security treasury (TGSS), relying on anti-money laundering rules. The AEPD found that this procedure involved processing without a valid legal basis (Art. 6(1) GDPR); the sanction of 2,000,000 EUR was reduced to 1,600,000 EUR after voluntary payment without admission of liability, and remedial measures were also ordered.

What organisations can take from it

Anyone relying on consent for queries to public authorities must obtain it freely and must not make opening an account conditional on it.

Relevance to training and awareness

Legal basis for data queries in anti-money laundering checks

Authority / court
Agencia Española de Protección de Datos (AEPD)
Area of law
Data protection
Legal basis
Art. 6 Abs. 1 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
20% reduction for voluntary payment (Art. 85 LPACAP), without admission of liability.
Published
13 May 2025

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

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11 Mar 2025 Mooney S.p.A.Banca d'Italia fines Mooney €2.5m for anti-money laundering failings ItalyInternal controls €2.5m

The Banca d'Italia (Bank of Italy) imposed a fine of 2,500,000 EUR on Mooney S.p.A. under Art. 62 of Legislative Decree 231/2007. An on-site inspection from 23 October 2023 to 26 January 2024 had found shortcomings in organisation and internal controls relating to customer profiling, customer due diligence and suspicious transaction reporting, as well as unreported suspicious transactions. In setting the amount, the authority took into account the seriousness of the breaches, the company's turnover and the remedial action it had begun.

What organisations can take from it

Firms that do not embed customer profiling, due diligence and suspicious transaction reporting in robust processes and controls risk fines running into millions, even if they remedy the gaps later.

Relevance to training and awareness

Suspicious transaction reporting and risk-based customer due diligence

Authority / court
Banca d'Italia
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 7, 16–20, 24, 25, 35, 36 und 62 D.Lgs. 231/2007; Bestimmungen der Banca d'Italia vom 26.03.2019 und 30.07.2019; Art. 145 TUB i. V. m. Art. 65 D.Lgs. 231/2007
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The Banca d'Italia took the remedial action already initiated into account.
Liability of senior managers
Measures against individuals are not reported here.
Published
27 May 2025

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

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11 Mar 2025 Intra DTVM Ltda.Intra DTVM: CVM fine of BRL 1.2m for missing fund filings BrazilDisclosure and reporting obligations €188,419

The board of the Comissão de Valores Mobiliários (CVM, Brazilian Securities and Exchange Commission) fined the fund administrator Intra DTVM Ltda. BRL 1,200,000.00 for filing mandatory periodic information on the investment funds it administered late or not at all (Art. 59 Instrução CVM 555). According to the charges, 121 mandatory documents for 12 of the 19 funds it administered were missing at the end of the 2020 financial year; the company was acquitted of the charge of breaching its duty of diligence on a tied vote, since in that event the view more favourable to the accused prevails. An appeal against the decision is pending before the Conselho de Recursos do Sistema Financeiro Nacional (CRSFN, financial system appeals board). The decision is not final.

What organisations can take from it

Fund administrators need a robust deadline and control system so that mandatory information for every fund reaches the regulator on time.

Relevance to training and awareness

Timely mandatory filings with the regulator

Authority / court
Comissão de Valores Mobiliários (CVM)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Instrução CVM nº 555/2014, Art. 59
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
18 Mar 2025

Original amount 1,200,000 BRL, converted at the ECB reference rate of 11 Mar 2025.

Checked against the official source on 3 Oct 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

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

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6 Mar 2025 Talanx AGBaFin fines Talanx €1.095m for late notice on its half-yearly report GermanyDisclosure and reporting obligations €1.1m

On 6 March 2025 BaFin (German Federal Financial Supervisory Authority) imposed a fine of 1,095,000 EUR on Talanx AG. The company had not announced on time from when and at which web address its half-yearly financial report for the 2022 financial year was publicly available in addition to the company register. The fine is final.

What organisations can take from it

Even a seemingly formal availability notice carries fines; financial reporting deadlines belong in the compliance calendar.

Relevance to training and awareness

Meeting deadlines for financial report availability notices

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
§ 115 Abs. 1 S. 2 WpHG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
25 Mar 2025

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

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5 Mar 2025 Crystal Currency Exchange Inc.FINTRAC: CAD 348,067.50 penalty on Crystal Currency Exchange Inc. for 9 violations of anti-money laundering obligations CanadaSuspicious activity reports €226,047

According to FINTRAC, Crystal Currency Exchange Inc. is a money services business based in Burnaby, British Columbia. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 348,067.50 on the company on 5 March 2025. According to FINTRAC's findings, made during a compliance examination, the company committed 9 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, large cash transaction reporting, international electronic funds transfer reporting, appointing a compliance officer, written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the compliance training programme and the prescribed review of the compliance programme. Specifically, FINTRAC found three missing suspicious transaction reports and several unreported series of cash receipts and incoming and outgoing international transfers that together reached at least CAD 10,000 within 24 hours. According to FINTRAC, the company has appealed the decision to the Federal Court. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Crystal Currency Exchange Inc.", published 29 May 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-05-29-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9.6(1); PCMLTF Regulations 30(1)(a), 30(1)(b), 30(1)(c), 156(1)(a), 156(1)(b), 156(1)(c), 156(1)(d), 156(1)(e), 156(1)(f), 156(3); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
29 May 2025

Original amount 348,067.5 CAD, converted at the ECB reference rate of 5 Mar 2025.

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money laundering in small financial service providers

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

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

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3 Mar 2025 Cambrian Credit UnionFINTRAC: CAD 116,160 penalty on Cambrian Credit Union for 4 violations of anti-money laundering obligations CanadaSuspicious activity reports €76,907

According to FINTRAC, Cambrian Credit Union is a credit union based in Winnipeg, Manitoba. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 116,160 on the company on 3 March 2025. According to FINTRAC's findings, made during a compliance examination in 2023, the company committed 4 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, international electronic funds transfer reporting, written compliance policies and procedures and assessing and documenting money laundering and terrorist financing risks. Specifically, according to FINTRAC, one suspicious transaction report and two reports of incoming international transfers were missing; policies on ongoing monitoring and the risk assessment were insufficiently documented. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Cambrian Credit Union", published 10 June 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-06-10-eng; summarised in our own words; not an official version and not a reproduction of the original.

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

Original amount 116,160 CAD, converted at the ECB reference rate of 3 Mar 2025.

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

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28 Feb 2025 Allianz Australia Insurance Limited; AWP Australia Pty LtdAllianz and AWP: criminal fines of AUD 16.8m over misleading travel insurance information AustraliaMisleading advertising and pricing €10m

Between 2016 and 2018 Allianz Australia and AWP, the company marketing and administering travel insurance on Allianz’s behalf, published online information on travel insurance that stated maximum benefits without adequately pointing out sub-limits, conditions and exclusions. The Court convicted Allianz on six counts at AUD 2.25 million each (AUD 13.5 million) and AWP on one count at AUD 3.3 million, in each case after a 25% discount for early guilty pleas. 781 customers had previously received compensation totalling AUD 1,264,864.

What organisations can take from it

Saving on the legal review of web content can cost many times more in fines and compensation; product advertising needs a mandatory sign-off.

Relevance to training and awareness

Legal review of product information and advertising pages before publication

Authority / court
Supreme Court of New South Wales (Anklage des Commonwealth Director of Public Prosecutions nach Ermittlungen der ASIC)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
ss 1041E(1), 1311(1) Corporations Act 2001 (Cth)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Repeat case
yes
Mitigating circumstances
Guilty pleas at the earliest opportunity, voluntary disclosure, full cooperation with the investigating authorities and compensation of affected customers.
Liability of senior managers
In 2016 a General Manager declined an external legal review of the website estimated at AUD 25,000 to 30,000; the Court saw the cause of the offences in an unwillingness to spend money on adequate oversight.
Published
28 Feb 2025

Original amount 16,800,000 AUD, converted at the ECB reference rate of 28 Feb 2025.

Checked against the official source on 3 Oct 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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27 Feb 2025 Rogaland SparebankRogaland Sparebank: NOK 1.2m fine for failing to freeze an account NorwayBreaches of sanctions and embargoes €102,551

Gulating lagmannsrett (Gulating Court of Appeal) sentenced Rogaland Sparebank (formerly Sandnes Sparebank) to a corporate fine of NOK 1,200,000 because in April and May 2020 the bank failed to freeze an account opened in the name of a person on the UN Al-Qaida sanctions list and booked 13 payments totalling NOK 45,828 to it; the bank must also pay NOK 50,000 in legal costs. Hordaland tingrett (district court) had initially acquitted the bank; on 21 May 2025 the appeals committee of the Høyesterett (Supreme Court) refused leave for the bank's appeal.

What organisations can take from it

Suspicious transaction reporting does not replace sanctions screening: funds of listed persons must be frozen immediately, even if the account was formally opened at the request of a third party.

Relevance to training and awareness

Freezing funds of sanctioned persons

Authority / court
Gulating lagmannsrett
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
§ 2 lov om bindende FN-vedtak i. V. m. § 3 forskrift om sanksjoner mot ISIL (Da'esh) og Al-Qaida; §§ 27 und 28 straffeloven
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The bank discovered the matter itself, took measures and reported it to Økokrim and later to Finanstilsynet and the Ministry of Foreign Affairs; it gained nothing from the breach.
Liability of senior managers
According to the court of appeal, it is the responsibility of management and the board to staff the bank so that sanctions obligations are complied with.

Original amount 1,200,000 NOK, converted at the ECB reference rate of 27 Feb 2025.

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

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25 Feb 2025 Cantor Fitzgerald Ireland LimitedCentral Bank: €452,790 fine against Cantor Fitzgerald for failing to report suspicions IrelandMarket abuse and insider dealing €452,790

Between March 2017 and June 2023 the investment firm on several occasions failed to report identified suspicious transactions to the Central Bank, did not consistently document its assessments and did not reliably escalate suspicions internally. For breaching Art. 16(2) MAR, the Central Bank imposed €452,790 after a 30% settlement discount (base amount €646,840); the breach was admitted.

What organisations can take from it

Front-office brokers must document and escalate suspicions, and the firm must actually report identified suspicious transactions.

Relevance to training and awareness

Recognising and escalating suspicious orders by traders and brokers

Authority / court
Central Bank of Ireland
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 16(2) Verordnung (EU) Nr. 596/2014 (MAR); European Union (Market Abuse) Regulations 2016 (S.I. No. 349 of 2016)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
30% settlement discount; breach admitted.
Published
27 Feb 2025

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

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21 Feb 2025 Royal Bank of Canada, Morgan Stanley, HSBC u. a. (5 Banken; Deutsche Bank als Kronzeugin bußgeldfrei)CMA: GBP 104.46m fine for four banks over information exchange on gilts United KingdomCartels and collusion €126.2m

The CMA issued five separate decisions finding that, between 2009 and 2013, pairs of banks had exchanged competitively sensitive information on trading UK government bonds (gilts and gilt asset swaps), and in part on Debt Management Office auctions and Bank of England buy-back auctions, in bilateral Bloomberg chats between individual traders. Under settlement, Royal Bank of Canada pays 34,200,000, Morgan Stanley 29,700,000, HSBC 23,400,000 and Citi 17,160,000 GBP, GBP 104,460,000 in total; Deutsche Bank, which had reported the exchanges, was not fined.

What organisations can take from it

Chats between traders at different firms are a cartel risk: even occasional exchanges of pricing and auction information can amount to a restriction of competition by object.

Relevance to training and awareness

Information exchange between competitors in trader chats

Authority / court
Competition and Markets Authority (CMA)
Area of law
Competition law · Cartels and collusion
Legal basis
Chapter I prohibition, section 2(1) Competition Act 1998
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
Citi: 35% leniency discount and 20% settlement discount; HSBC, Morgan Stanley and RBC: 10% settlement discount. The CMA also took into account the time elapsed since the infringements ended and the banks' extensive compliance measures, some of which pre-dated the investigation.
Published
21 Feb 2025

Original amount 104,460,000 GBP, converted at the ECB reference rate of 21 Feb 2025.

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

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21 Feb 2025 AustralianSuper (Trustee des Pensionsfonds AustralianSuper)AustralianSuper: AUD 27m penalty for failing to merge duplicate member accounts AustraliaOrganisational requirements €16.5m

From July 2013 to March 2023 the trustee of Australia’s largest superannuation fund did not merge the duplicate accounts of around 90,700 members, although s 108A of the SIS Act requires this; members lost around AUD 69 million through duplicate fees, insurance premiums and lost earnings. The Court found a breach of fundamental trustee obligations and imposed AUD 27 million; all affected members have been remediated.

What organisations can take from it

Known compliance gaps must be escalated and remedied with sufficient resources; lack of staff is no excuse.

Relevance to training and awareness

Escalating and remedying identified compliance gaps that harm customers

Authority / court
Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
ss 52, 108A Superannuation Industry (Supervision) Act 1993 (Cth)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Self-report of potential breaches to ASIC in December 2021; remediation of all affected members.
Liability of senior managers
According to the judgment, issues were not escalated and senior management oversight was absent; under-resourcing delayed the remedy.
Published
21 Feb 2025

Original amount 27,000,000 AUD, converted at the ECB reference rate of 21 Feb 2025.

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

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19 Feb 2025 Wechselstube (anonymisiert, Sanktion vom 19.02.2025)CBUAE: AED 3.5m on an exchange house for AML breaches United Arab EmiratesInternal controls €913,388

Following an examination, the Central Bank found that an unnamed exchange house had not complied with its policies and procedures for combating money laundering and terrorist financing. The CBUAE imposed a financial sanction of AED 3.5 million.

What organisations can take from it

Exchange houses are under close AML supervision – gaps between policy and practice are punished with sums in the millions.

Relevance to training and awareness

AML prevention in exchange houses

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

Original amount 3,500,000 AED, converted at the ECB reference rate of 19 Feb 2025.

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

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19 Feb 2025 Smart Home Ensured LimitedICO: Enforcement notice against Smart Home Ensured over marketing calls United KingdomMarketing and consent Order

The ICO issued an enforcement notice to Smart Home Ensured Limited. The ICO found that between July and August 2023 the company made 14,508 unsolicited marketing calls to numbers that had been registered with the Telephone Preference Service for at least 28 days. The notice requires the company to stop such calls. The notice is an enforcement notice and does not impose a fine.

Authority / court
Information Commissioner's Office (ICO)
Area of law
Data protection · Marketing and consent
Legal basis
Regulation 21 PECR; section 40 DPA 1998 (Enforcement Notice)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance

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

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17 Feb 2025 Mako Financial Markets Partnership LLPFCA: £1.66m fine for Mako over control failings in OTC equity trading United KingdomInternal controls €2m

The FCA fined Mako Financial Markets Partnership LLP £1,662,700, of which £1,137,283 is disgorgement. The FCA found that between December 2013 and November 2015 Mako executed over-the-counter trades for clients introduced by another broker group, without adequate systems and controls against fraud and money laundering. Customer due diligence and transaction monitoring were, in the FCA's view, inadequate, and red flags in certain equity trades were missed. The fine includes a settlement discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
FCA Principles 2 und 3; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 1,662,700 GBP, converted at the ECB reference rate of 17 Feb 2025.

Checked against the official source on 28 Sep 2026 · Version 2 · 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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4 Feb 2025 Deutsche Bank AGBaFin fines Deutsche Bank €23.05m for organisational and recording failings GermanyOrganisational requirements €23.1m

On 4 February 2025 BaFin (German Federal Financial Supervisory Authority) imposed fines totalling 23,050,000 EUR on Deutsche Bank AG: 14.8 million EUR because, following allegations about the sale of currency derivatives in Spain, the bank took too long to investigate and remedy the shortcomings; 4.6 million EUR because its Postbank branch at times did not record telephone conversations relating to client orders; and 3.65 million EUR because Postbank failed to provide account-switching assistance in 53 cases. The fine is final.

What organisations can take from it

Compliance allegations abroad must be investigated and remedied swiftly; slow remediation is itself an organisational breach.

Relevance to training and awareness

Complying with recording duties in investment services and account-switching assistance

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
§ 80 Abs. 1 S. 2 Nr. 1 WpHG; § 130 Abs. 1 OWiG i. V. m. § 83 Abs. 3 S. 1 WpHG; §§ 22, 23 Abs. 1 ZKG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
For the telephone-recording complex, a breach of the duty of supervision (§ 130 OWiG, German Administrative Offences Act) was sanctioned: after the pandemic exemptions expired, monitoring and organisational measures were lacking at times.
Published
4 Mar 2025

Checked against the official source on 2 Oct 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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27 Jan 2025 Hang Seng Bank LimitedHang Seng Bank: HKD 66.4m fine over selling practices and excessive charges Hong KongOrganisational requirements €8.1m

Hang Seng Bank was publicly reprimanded and fined 66,400,000 HKD. Relationship managers had induced 46 clients, whose fund transactions in 2016/2017 were recorded as their own choice, to trade excessively often with short holding periods; between 2014 and 2018, 388 clients without established knowledge of derivatives bought derivative funds in 629 transactions; and between 2014 and 2023 the bank improperly retained benefits, overcharged fees and inadequately disclosed trailer fees (at least 22.4 million HKD). The bank has compensated affected clients and refunded the amounts overcharged.

What organisations can take from it

Client transactions flagged as the client's own choice and fee billing need independent control, otherwise mis-selling and overcharging go undetected for years.

Relevance to training and awareness

Investment advice: suitability, excessive trading and fee transparency

Authority / court
Securities and Futures Commission (SFC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
s. 196 SFO (Cap. 571); Code of Conduct for Persons Licensed by or Registered with the SFC
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Compensation of clients and refund of benefits, internal and independent reviews after self-reporting, cooperation with the Hong Kong Monetary Authority (HKMA) and the Securities and Futures Commission (SFC) and acceptance of the findings, no previous disciplinary record.
Published
27 Jan 2025

Original amount 66,400,000 HKD, converted at the ECB reference rate of 27 Jan 2025.

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27 Jan 2025 Infinox Capital LimitedFCA: £99,200 fine for Infinox over missing transaction reports United KingdomDisclosure and reporting obligations €117,946

The FCA fined Infinox Capital Limited £99,200. The FCA found that between October 2022 and March 2023 the firm failed to report to the FCA trades from its single-stock CFD business routed through one corporate account. In total 46,053 transaction reports were missing and were only back-reported in December 2023. The fine includes a 30% settlement discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 26(1) UK MiFIR; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 99,200 GBP, converted at the ECB reference rate of 27 Jan 2025.

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

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24 Jan 2025 The Standard Bank of South Africa LimitedPA: ZAR 13m against Standard Bank over late reports to the FIC South AfricaSuspicious activity reports €675,255

Following an inspection in 2022, the supervisor found that the bank had filed 17,259 suspicious transaction reports and 1,466 cash transaction reports late and failed to file one suspicious report at all, had not recorded the submission dates of 43 suspicious reports, omitted ongoing due diligence on two clients and not handled some 75,700 monitoring alerts on time. Sanction: six cautions and financial penalties totalling ZAR 13m (4m for late suspicious reports, 1m for the missing report, 8m for breaches of Directive 5). The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Identifying suspicious cases but not reporting them on time breaches the reporting duty just as not reporting at all does; reporting processes need capacity and deadline control.

Relevance to training and awareness

Timely suspicious and cash transaction reporting

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 21C, 23(c), 28, 29; FIC Directive 5 of 2019; Regulation 24(3)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
The bank's cooperation and remedial action.
Published
24 Jan 2025

Original amount 13,000,000 ZAR, converted at the ECB reference rate of 24 Jan 2025.

Checked against the official source on 4 Oct 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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22 Jan 2025 Kakaopay Corp.Kakao Pay: 5.968 billion KRW for transferring user data to Alipay without consent South KoreaInternational data transfers €3.99m

Kakaopay Corp. transferred data on all users three times in 2018 and, from June 2019 to May 2024, data on around 40 million users every day without consent to Alipay in Singapore, which used it to calculate for Apple a score for the likelihood of insufficient funds on bundled App Store payments (NSF score). The authority treated this as an unlawful transfer abroad, imposed a penalty surcharge of 5,968,000,000 KRW and ordered remediation and publication of the decision on the company’s website. In separate decisions on the same day Apple received a penalty surcharge of 2,405,000,000 KRW and an administrative fine of 2,200,000 KRW, and Alipay was ordered to delete the scoring model.

What organisations can take from it

Anyone passing customer data to a partner’s foreign service provider must check whether this is a transfer requiring consent and limit the data to what is necessary.

Relevance to training and awareness

Data sharing with partners’ foreign service providers

Authority / court
Personal Information Protection Commission (PIPC, 개인정보보호위원회)
Area of law
Data protection · International data transfers
Legal basis
Personal Information Protection Act (개인정보 보호법) Art. 28-8(1); Sanktion nach Art. 64-2(1) Nr. 9
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Reduction of 30% for completed remediation, cooperation and ISMS-P certification; increase of 50% because the infringement lasted more than two years (June 2019 to May 2024).
Published
23 Jan 2025

Original amount 5,968,000,000 KRW, converted at the ECB reference rate of 22 Jan 2025.

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

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21 Jan 2025 Banco di Desio e della Brianza S.p.A.Banca d'Italia fines Banco di Desio €480,000 over customer transparency failings ItalyConsumer protection and online retail €480,000

The Banca d'Italia (Bank of Italy) imposed a fine of 480,000 EUR on Banco di Desio e della Brianza S.p.A. under Art. 144 of the Consolidated Banking Act (TUB). An inspection from 2 October to 15 December 2023 found shortcomings in organisation and controls for compliance with the rules on transparency and fair treatment of customers, including Arts. 117-bis, 126-septies and 126-quinquiesdecies et seq. TUB; the bank's corrective measures were taken into account.

What organisations can take from it

Transparency duties towards customers need their own controls within the organisation; where these are missing, the supervisor sanctions the bank even if individual errors are corrected later.

Relevance to training and awareness

Transparency and fair treatment of bank customers

Authority / court
Banca d'Italia
Area of law
Consumer protection and online retail
Legal basis
Art. 127 Abs. 01 TUB i. V. m. Art. 117-bis, 126-septies und 126-quinquiesdecies bis 126-septiesdecies TUB; Transparenzbestimmungen der Banca d'Italia vom 29.07.2009; Art. 144 TUB
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The bank's corrective measures were taken into account in setting the fine.
Published
14 Mar 2025

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

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17 Jan 2025 Equifax Inc. und Equifax Information Services LLCCFPB: Equifax pays 15 million USD over flawed handling of credit report disputes USAConsumer protection and online retail €14.6m

According to the CFPB, Equifax did not properly reinvestigate disputes about credit report entries, allowed deleted entries to be reinserted, informed consumers inadequately of the results and did not block entries resulting from identity theft as required (Fair Credit Reporting Act). The company also sold inaccurate credit scores after test code had been introduced into a production server; the order imposes a fine of 15 million USD. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Data corrections must be lasting, and software changes may only reach production systems after testing.

Relevance to training and awareness

Dispute handling and change management for credit bureau data

Authority / court
Consumer Financial Protection Bureau (CFPB)
Area of law
Consumer protection and online retail
Legal basis
Fair Credit Reporting Act (15 U.S.C. §§ 1681c, 1681e, 1681i); Consumer Financial Protection Act of 2010, §§ 1031, 1036
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
17 Jan 2025

Original amount 15,000,000 USD, converted at the ECB reference rate of 17 Jan 2025.

Checked against the official source on 3 Oct 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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16 Jan 2025 Block, Inc. (Cash App)CFPB: Block (Cash App) must pay at least 130 million USD over fraud handling USAConsumer protection and online retail €53.5m

The CFPB found that Block did not effectively prevent and address fraud on Cash App, handled disputes and chargebacks unfairly, did not provide effective customer service, misled users about protection against unauthorised transfers and breached error-resolution duties under the Electronic Fund Transfer Act and Regulation E. The order imposes a fine of 55 million USD and requires 75 million USD for redress, which may rise to up to 120 million USD (up to 175 million USD in total). The authority allegedly made the findings set out here; this account is not based on a final judgment. The amount field records only the civil monetary penalty.

What organisations can take from it

Payment services must be reachable for fraud reports and investigate them on time – security promises in advertising are measured against this.

Relevance to training and awareness

Handling fraud reports and disputes in payment apps

Authority / court
Consumer Financial Protection Bureau (CFPB)
Area of law
Consumer protection and online retail
Legal basis
Consumer Financial Protection Act of 2010 (12 U.S.C. §§ 5531, 5536); Electronic Fund Transfer Act und Regulation E (12 C.F.R. §§ 1005.6, 1005.7, 1005.11, 1005.13, 1005.18)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
16 Jan 2025

Original amount 55,000,000 USD, converted at the ECB reference rate of 16 Jan 2025.

Sources

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

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15 Jan 2025 Danske Bank A/SDanske Bank: NOK 50m for market manipulation in government bond issue NorwayMarket abuse and insider dealing €4.27m

Finanstilsynet (Norwegian Financial Supervisory Authority) fined Danske Bank A/S NOK 50,000,000 for market manipulation. In the syndication of a ten-year Norwegian government bond of NOK 22 billion in February 2023, whose yield was priced off the Norwegian swap rate, the bank, through its Norwegian branch, pushed the reference rate to an artificial level with interest rate swap trades concentrated around the pricing time, in a situation where it benefited from a higher yield. The fact that the bank had itself approached the supervisory authorities was taken into account as a mitigating factor.

What organisations can take from it

Hedging trades around the setting of reference prices need clear controls so that they are not treated as price manipulation.

Relevance to training and awareness

Market manipulation around reference prices and new issues

Authority / court
Finanstilsynet
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 15 i. V. m. Art. 12 Abs. 1 lit. a MAR; § 3-1, §§ 21-1, 21-9 und 21-14 verdipapirhandelloven; § 46 forvaltningsloven
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
The bank had itself approached the supervisory authorities.
Published
22 Jan 2025

Original amount 50,000,000 NOK, converted at the ECB reference rate of 15 Jan 2025.

Checked against the official source on 28 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 Markom Management LimitedOFSI: GBP 300,000 penalty for Markom Management over a refund to a designated person United KingdomBreaches of sanctions and embargoes €358,453

On 10 January 2025 OFSI imposed a monetary penalty of GBP 300,000 on the UK company Markom Management Limited, which in 2018 provided fiduciary, administration and bookkeeping services to companies. According to OFSI's findings, on 20 February 2018 the company instructed the return of an overpayment of around GBP 416,590 to a person designated under EU law, thereby making funds directly available to that person. OFSI attributed this to a lack of processes, poor knowledge of sanctions and a wish to make the payment quickly. The company reported the breach in October 2018; OFSI did not grant a disclosure discount. The notice of intent of 1 August 2024 had proposed GBP 400,000; after representations from the company OFSI reduced the amount. A ministerial review upheld the penalty on 4 June 2025. The publication does not mention any pending review. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Imposition of monetary penalty: Markom Management Limited", 31 July 2025, https://www.gov.uk/government/publications/imposition-of-monetary-penalty-markom-management-limited. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

Authority / court
HM Treasury, Office of Financial Sanctions Implementation (OFSI)
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Ukraine (European Union Financial Sanctions) (No. 2) Regulations 2014 (Umsetzung der Verordnung (EU) Nr. 269/2014); Geldbuße nach s. 146 Policing and Crime Act 2017
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
31 Jul 2025

Original amount 300,000 GBP, converted at the ECB reference rate of 10 Jan 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · 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 ein kleiner britischer BrokerFCA: small broker 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
Employees
Under 50
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.

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

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6 Jan 2025 Gemini Trust Company, LLCGemini Trust: 5 million USD over misleading statements to the CFTC USADisclosure and reporting obligations €4.8m

On a complaint by the CFTC, the federal court in New York ordered the New York trust company, in a consent order, to pay a fine of 5 million USD and imposed a permanent injunction. In 2017, in connection with the self-certification of a bitcoin futures contract that referenced an auction on Gemini, Gemini made statements to the CFTC, or omitted facts, that it should reasonably have known were false or misleading, for example on its prefunding requirement, self-trade prevention, fee rebates and trading volume and liquidity. These statements were material to the assessment of whether the contract was susceptible to manipulation. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

What a company tells the supervisor to assess a product must be complete and reliable; statements made by its representatives are attributed to it.

Relevance to training and awareness

Truthful statements to supervisory authorities

Authority / court
U.S. District Court for the Southern District of New York (auf Klage der CFTC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Section 6(c)(2) Commodity Exchange Act (7 U.S.C. § 9(2))
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
13 Jan 2025

Original amount 5,000,000 USD, converted at the ECB reference rate of 6 Jan 2025.

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

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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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26 Dec 2024 株式会社イオン銀行 (AEON Bank, Ltd.)AEON Bank: order over 14,639 unreviewed money laundering alerts JapanSuspicious activity reports Order

Between June and November 2023 and between July and September 2024, the bank failed to assess at least 14,639 transactions flagged by its transaction monitoring for whether suspicious transaction reports were needed, and took up to 152 days on monthly average to file reports (February 2024). It had also not implemented the measures required by the supervisory AML/CFT guidelines by the end-March 2024 deadline and had not remedied findings from the previous inspection. The business improvement order under Art. 26(1) of the Banking Act requires, among other things, the outstanding reviews and reports to be completed and governance by the board and management to be fundamentally strengthened.

What organisations can take from it

Transaction monitoring only works with enough staff to assess every alert promptly; backlogs must reach the board.

Relevance to training and awareness

Prompt handling of monitoring alerts and suspicious transaction reports

Authority / court
Financial Services Agency (FSA, 金融庁)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Banking Act (銀行法) Art. 26 Abs. 1; Act on Prevention of Transfer of Criminal Proceeds (犯罪収益移転防止法); Guidelines for AML/CFT der FSA
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Liability of senior managers
According to the reasons, the board and management neither established the facts themselves nor gave instructions despite repeated signals from backlogs, inspection findings and internal audit; the order requires responsibility to be clarified.
Published
26 Dec 2024

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23 Dec 2024 MMM Holdings, LLCMMM Holdings: USD 15.2m over gift cards for Medicare plan enrolments USAGifts, hospitality and benefits €14.7m

The Puerto Rico Medicare Advantage provider pays USD 15,228,340 to resolve False Claims Act and Anti-Kickback Statute allegations and entered into a five-year Corporate Integrity Agreement with HHS-OIG. From January 2018 to December 2022 MMM allegedly gave gift cards to administrative assistants of medical practices so that they would get thousands of Medicare beneficiaries to enrol in an MMM plan; the resulting premium payments amounted to USD 6,091,336.

What organisations can take from it

Gifts to practice staff who advise insured patients are as sensitive as benefits to doctors.

Relevance to training and awareness

Gifts to practice staff who advise or refer patients

Authority / court
U.S. Attorney's Office, District of Puerto Rico; HHS Office of Inspector General (HHS-OIG)
Area of law
Bribery and corruption · Gifts, hospitality and benefits
Legal basis
False Claims Act; Anti-Kickback Statute
Action
Other
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The company's cooperation and its implementation of internal controls were taken into account.
Published
23 Dec 2024

Original amount 15,228,340 USD, converted at the ECB reference rate of 23 Dec 2024.

Checked against the official source on 3 Oct 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 28 Sep 2026 · Version 2 · Direct link

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20 Dec 2024 Argosy Securities Inc.FINTRAC: CAD 66,000 penalty on Argosy Securities Inc. for 3 violations of anti-money laundering obligations CanadaInternal controls €44,159

According to FINTRAC, Argosy Securities Inc. is a securities dealer or wealth management firm based in Richmond Hill, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 66,000 on the company on 20 December 2024. According to FINTRAC's findings, made during a compliance examination, the company committed 3 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks and the prescribed review of the compliance programme. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Argosy Securities Inc.", published 13 February 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-02-13-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTF Regulations 156(1)(b), 156(1)(c), 156(1)(f), 156(2), 156(3); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
13 Feb 2025

Original amount 66,000 CAD, converted at the ECB reference rate of 20 Dec 2024.

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

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19 Dec 2024 Provident Financial s.r.o.ČNB: CZK 8m fine for Provident Financial over deficient creditworthiness assessments CzechiaConsumer protection and online retail €318,383

Following an objection to a penalty order, the ČNB (Czech National Bank) fined the non-bank consumer lender Provident Financial 8,000,000 CZK. From October 2021 to October 2022 the creditworthiness rules for the products “Půjčka Provident” and “Půjčka Creditea” allowed, among other things, unverified or overstated income, insufficiently established or entirely disregarded expenses and understated liabilities, and in every contract examined (53 and 25 respectively) the company granted loans without an adequate creditworthiness assessment. The ČNB Bank Board dismissed the appeal on 15 May 2025 and upheld the decision.

What organisations can take from it

Creditworthiness assessments must capture income, expenses and existing debts completely and verifiably; simplified models that leave out burdens are a supervisory risk.

Relevance to training and awareness

Responsible lending and verification of income and expenses

Authority / court
Česká národní banka (ČNB)
Area of law
Consumer protection and online retail
Legal basis
§ 15 Abs. 1 i. V. m. Abs. 2 lit. c, § 86 Abs. 1, § 148 Abs. 1 lit. b, § 154 Abs. 1 lit. e und Abs. 3 lit. c Zákon č. 257/2016 Sb. (Verbraucherkreditgesetz, Fassung bis 31. 12. 2023)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 8,000,000 CZK, converted at the ECB reference rate of 19 Dec 2024.

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

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19 Dec 2024 MSBG International Holdings Ltd.FINTRAC: CAD 24,750 penalty on MSBG International Holdings Ltd. for one violation of anti-money laundering obligations CanadaInternal controls €16,577

According to FINTRAC, MSBG International Holdings Ltd. is a money services business based in Vancouver, British Columbia. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 24,750 on the company on 19 December 2024. According to FINTRAC's findings, made during a compliance examination in 2023, the company committed one violation of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violation concerned written compliance policies and procedures. According to FINTRAC, the penalty has been paid in full and the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on MSBG International Holdings Ltd.", published 25 February 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-02-25-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTF Regulations 71(1)(b); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
25 Feb 2025

Original amount 24,750 CAD, converted at the ECB reference rate of 19 Dec 2024.

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

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19 Dec 2024 Citibank Europe Plc, Luxembourg BranchCitibank Europe, Luxembourg Branch: reprimand for late implementation of Russia sanctions LuxembourgBreaches of sanctions and embargoes Reprimand or warning

The CSSF issued a reprimand to the Luxembourg branch because in 2022 it implemented financial sanctions under Regulation (EU) No 269/2014 late in respect of two accounts of a listed client and informed the Ministry of Finance late. Automatic fee and interest postings continued on the accounts; according to the CSSF, the listed person did not access any funds.

What organisations can take from it

New sanctions listings must be applied to all accounts and reported to the Ministry of Finance without delay – automatic postings also need to be checked.

Relevance to training and awareness

Freezing and reporting without delay after new sanctions listings

Authority / court
Commission de Surveillance du Secteur Financier (CSSF)
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Art. 6(4) Loi du 19 décembre 2020 relative aux mesures restrictives en matière financière; Art. 8-4(1) und (2) Loi modifiée du 12 novembre 2004 (LBC/FT); verletzt Art. 2 und 7 VO (EU) Nr. 269/2014, Art. 6(1) Gesetz 2020, Règlement grand-ducal du 14 novembre 2022, Art. 33(2) Règlement CSSF 12-02
Action
Reprimand or warning
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The CSSF took into account the branch's remedial measures.
Published
12 Feb 2025

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18 Dec 2024 Bank, Polen (anonymisiert)UODO: PLN 576,220 for a bank over a non-independent DPO and no DPIA on scoring PolandData protection €135,333

The data protection officer of a bank in Poland did not report directly to the bank's management but to a department director who was also responsible for processing operations; in addition, the profiling used for credit scoring was missing from the record of processing activities and from a data protection impact assessment. The Polish data protection authority UODO imposed fines of PLN 261,918 and PLN 314,302, totalling PLN 576,220.

What organisations can take from it

The data protection officer must report directly to senior management, and scoring-related profiling must be covered in the record of processing and in a DPIA.

Relevance to training and awareness

Independence of the data protection officer and impact assessment for profiling

Authority / court
Prezes Urzędu Ochrony Danych Osobowych (UODO)
Area of law
Data protection
Legal basis
Art. 38 Abs. 3, Art. 30 Abs. 1, Art. 35 Abs. 1 und 7 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
20 Jan 2025

Original amount 576,220 PLN, converted at the ECB reference rate of 18 Dec 2024.

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

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16 Dec 2024 Jyske Bank A/SJyske Bank: almost DKK 24m over anti-money-laundering failings in Keyplan Mortgage unit DenmarkCustomer due diligence €3.21m

Jyske Bank accepted a fine notice (bødeforelæg) of 23,961,500 DKK from the National enhed for Særlig Kriminalitet (NSK, Danish National Special Crime Unit). It followed a report by the Finanstilsynet (Danish Financial Supervisory Authority) of November 2022 after an anti-money-laundering inspection of the Keyplan Mortgage unit: the bank had not applied sufficient customer due diligence and enhanced due diligence to customers classified as high-risk, and had not investigated suspicious transactions.

What organisations can take from it

High-risk customers in specialist units need the same enhanced checks and transaction monitoring as in the core business.

Relevance to training and awareness

Enhanced due diligence and transaction review for high-risk customers

Authority / court
National enhed for Særlig Kriminalitet (NSK) auf Anzeige des Finanstilsynet
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Hvidvaskloven § 11 stk. 1 nr. 4 og 5, § 17 stk. 1, § 25 stk. 1
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
16 Dec 2024

Original amount 23,961,500 DKK, converted at the ECB reference rate of 16 Dec 2024.

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

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16 Dec 2024 Finanzdienstleister (anonymisiert)Liechtenstein: CHF 75,000 fine for breaching Article 16(2) MAR LiechtensteinMarket abuse and insider dealing €80,026

The Finanzmarktaufsicht (FMA, Liechtenstein Financial Market Authority) fined an unnamed legal person CHF 75,000 for breaching the obligations under Article 16(2) of the Market Abuse Regulation (EU) No 596/2014. The provision requires persons professionally arranging or executing transactions to maintain effective arrangements, systems and procedures to detect and report suspicious orders and transactions.

What organisations can take from it

Anyone who professionally arranges or executes securities transactions needs working surveillance systems and clear procedures for reporting suspected market abuse.

Relevance to training and awareness

Detecting and reporting suspicious orders and transactions (market abuse)

Authority / court
Finanzmarktaufsicht Liechtenstein (FMA)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 16 Abs. 2 Verordnung (EU) Nr. 596/2014 (Marktmissbrauchsverordnung) i.V.m. Art. 10 Abs. 1 Bst. b EWR-Marktmissbrauchsverordnung-Durchführungsgesetz (EWR-MDG)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 75,000 CHF, converted at the ECB reference rate of 16 Dec 2024.

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13 Dec 2024 EcoR1 Capital LLCAMF: EUR 7 million on EcoR1 Capital over share price manipulation in Innate Pharma (under appeal) FranceMarket abuse and insider dealing €7m

The AMF (Autorité des marchés financiers, French financial markets authority) Enforcement Committee found that the US asset manager EcoR1 Capital, when selling Innate Pharma shares on five trading days in October 2019 immediately before the company's Nasdaq listing, manipulated the price within the meaning of Art. 12 MAR and also failed to notify crossing the 5% threshold upwards and downwards. It imposed EUR 7,000,000 on the company. The amount covers only the sanction imposed on the company. A further manipulation allegation was not upheld. The decision has been appealed.

What organisations can take from it

Anyone unwinding large positions ahead of a capital markets transaction must check the price impact of their orders and file threshold notifications on time.

Relevance to training and awareness

Market manipulation when unwinding positions, and major holding notifications

Authority / court
Autorité des marchés financiers (AMF), Commission des sanctions
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 12, 15 Verordnung (EU) Nr. 596/2014 (MAR); Art. L. 233-7 Code de commerce; Art. 223-14 Règlement général de l'AMF
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
16 Dec 2024

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

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13 Dec 2024 Aarna Capital LimitedADGM: allegedly 504,000 USD fine for broker Aarna Capital over KYC and monitoring failures United Arab EmiratesCustomer due diligence €479,179

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the broker for professional clients allegedly 504,000 USD for inadequate anti-money laundering controls between June 2017 and January 2023. In a review of 42 client relationships the regulator found that twelve clients should have been rated high risk because of relevant risk factors, so enhanced due diligence and annual reviews did not take place; documentation, risk-based updating of customer data, transaction monitoring and procedures to detect suspicious activity were also inadequate. The regulator identified no specific instances of money laundering; without the 20% discount for early settlement the fine would have been 630,000 USD.

What organisations can take from it

A risk rating that is too lenient undermines every downstream control, from enhanced due diligence to periodic review.

Relevance to training and awareness

Customer risk rating and ongoing transaction monitoring

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Section 232 FSMR 2015; AML Rules 4.1.1(1), 4.1.1(2)(a) und (d), 4.5.1(b), 4.5.3, 7.1.1, 8.1.2(1), 8.6.1(a), 14.2.1
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
No previous breaches of the AML rules (though earlier action over CRS reporting duties), cooperation and remediation including an external gap analysis (10% reduction); 20% discount for early settlement.

Original amount 504,000 USD, converted at the ECB reference rate of 13 Dec 2024.

Checked against the official source on 3 Oct 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.

Sources

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12 Dec 2024 Bit Trade Pty Ltd (Betreiber der Kryptobörse Kraken)Kraken operator Bit Trade: AUD 8m penalty for missing target market determination AustraliaOrganisational requirements €4.87m

From October 2021 Bit Trade offered more than 1,100 Australian customers a “margin extension” product, which the Court classified as a credit facility, without having made the required target market determination. Customers paid more than USD 7 million in fees and interest and suffered trading losses of more than USD 5 million. The Court imposed AUD 8 million; it was the first penalty for a missing target market determination.

What organisations can take from it

Crypto providers too must check whether their products are regulated financial products and make a target market determination before distribution.

Relevance to training and awareness

Product approval and target market determinations for new financial and crypto products

Authority / court
Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Design and Distribution Obligations des Corporations Act 2001 (Cth) (Pflicht zur Target Market Determination)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
12 Dec 2024

Original amount 8,000,000 AUD, converted at the ECB reference rate of 12 Dec 2024.

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

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12 Dec 2024 Großbank, Spanien (anonymisiert)AEPD: EUR 3.5 million fine on a major bank as an authorised person could view another account SpainData breaches and data security €3.5m

A person authorised for only two of the accounts of a customer of a major Spanish bank was able, in online banking, to view the financial information of a joint account held by the customer with another co-holder, for which that person had no authorisation. The Spanish data protection authority AEPD imposed EUR 500,000 (Art. 5(1)(f)) and EUR 3,000,000 for lack of data protection by design (Art. 25), EUR 3,500,000 in total, dropped the Art. 32 charge and ordered adjustments; the request for reconsideration was dismissed.

What organisations can take from it

Online banking permissions must be cleanly separated per account; an authorisation must not extend to other people's products.

Authority / court
Agencia Española de Protección de Datos (AEPD)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 5 Abs. 1 lit. f, Art. 25 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more

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11 Dec 2024 Hyundai Marine & Fire Insurance Co., Ltd.Hyundai Marine & Fire: 6.198 billion KRW for manipulative consent pop-up South KoreaMarketing and consent €4.12m

Hyundai Marine & Fire Insurance showed users of its online car insurance premium calculator who had declined consent to product marketing a further pop-up, swapped the effect of its buttons in July 2022 and mentioned neither the processing of data nor the mandatory information in it; the consents obtained in this way were invalid, and other insurers copied the pattern. The authority imposed a penalty surcharge of 6,198,000,000 KRW and ordered lawful consent, deletion of data from abandoned premium calculations and stronger internal controls with independent powers for the chief privacy officer. In the same session eleven further direct insurers were sanctioned, including AXA General Insurance (2,715,000,000 KRW) and Hana Insurance (273,000,000 KRW). The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

A refusal that is turned into consent by a second pop-up is not valid consent – consent flows belong with the data protection officer before launch.

Relevance to training and awareness

Dark patterns in marketing consent

Authority / court
Personal Information Protection Commission (PIPC, 개인정보보호위원회)
Area of law
Data protection · Marketing and consent
Legal basis
Personal Information Protection Act (개인정보 보호법, frühere Fassung) Art. 39-3(1), Art. 31(2), Art. 21(1); Sanktion nach Art. 39-15(1) Nr. 6 a. F.
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Reduction of 50% because no penalty had been imposed in the preceding three years, a further 30% for reasons including cooperation with the investigation and finally 40% following the Commission’s deliberations; increase of 25% because the infringement lasted from July 2022 to September 2023.
Liability of senior managers
Marketing and direct sales were able to design the consent flow without any involvement of the chief privacy officer (CPO); the authority found a breach of former Art. 31(2) and ordered that the CPO be given independent powers.
Published
12 Dec 2024

Original amount 6,198,000,000 KRW, converted at the ECB reference rate of 11 Dec 2024.

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

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11 Dec 2024 European High Growth Opportunities Manco SA; Alpha Blue Ocean Inc.; Auplata Mining Group; RSM ParisAMF: EUR 2.5 million in sanctions on four companies for market manipulation around Auplata's financing (under appeal) FranceMarket abuse and insider dealing €2.5m

The AMF (Autorité des marchés financiers, French financial markets authority) Enforcement Committee found market manipulation through misleading information in a press release issued by the gold mining company Auplata on 30 October 2017 about a financing agreement with the EHGO SF fund, in the notes to its 2017 consolidated accounts and in the report of its statutory auditor RSM Paris; in addition, the fund companies EHGO Manco and Alpha Blue Ocean were found to have manipulated the Auplata share price. EUR 1,000,000 each was imposed on EHGO Manco and Alpha Blue Ocean, EUR 300,000 on Auplata and EUR 200,000 on RSM Paris. The amount covers only the sanctions imposed on the companies. Several parties have appealed; Auplata has withdrawn its appeal.

What organisations can take from it

Issuers and auditors must present financing agreements and their consequences accurately; misleading statements can be sanctioned as market manipulation.

Relevance to training and awareness

Misleading financial communication and the responsibility of statutory auditors

Authority / court
Autorité des marchés financiers (AMF), Commission des sanctions
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 12 Abs. 1 lit. a und c, Art. 15 Verordnung (EU) Nr. 596/2014 (MAR)
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
12 Dec 2024

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10 Dec 2024 Klarna Bank ABKlarna: SEK 500m for gaps in money laundering risk assessment and procedures SwedenInternal controls €43.4m

Finansinspektionen (FI, Swedish Financial Supervisory Authority) issued Klarna a remark and an administrative fine of 500,000,000 SEK for breaches of the anti-money laundering act between 1 April 2021 and 31 March 2022. The general risk assessment lacked, among other things, assessments of how products and services could be misused for money laundering or terrorist financing; for the invoice product (faktura) there were no procedures capturing all situations requiring due diligence, and there was no procedure for model risk management. The maximum was based on the group's 2023 turnover of 24.64 billion SEK; the bank itself had a turnover of 19.65 billion SEK.

What organisations can take from it

Fast-growing payment providers must reflect every product in their money laundering risk assessment and maintain procedures for every trigger of due diligence obligations.

Relevance to training and awareness

Money laundering risk assessment for payment products and procedures for customer due diligence

Authority / court
Finansinspektionen (FI)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
2 kap. 1 och 8 §§ samt 6 kap. 1 § andra stycket lagen (2017:630) om åtgärder mot penningtvätt och finansiering av terrorism; 15 kap. 1 och 7 §§ lagen (2004:297) om bank- och finansieringsrörelse
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
FI did not treat cooperation, remediation or the proceedings' length of just over two and a half years as mitigating.
Published
11 Dec 2024

Original amount 500,000,000 SEK, converted at the ECB reference rate of 10 Dec 2024.

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10 Dec 2024 Versicherer, Spanien (anonymisiert)AEPD: EUR 4m fine for an insurer after access via a broker account SpainData breaches and data security €4m

Following several complaints about a data breach, the Spanish data protection authority AEPD found that an attacker using an insurance broker's credentials was able to access extensive data held by an insurer, including on former customers, because basic security measures, separation of datasets and an impact assessment were lacking. Fines of 1,000,000 EUR (Art. 5(1)(f)), 1,000,000 EUR (Art. 32), 2,000,000 EUR (Art. 25) and 1,000,000 EUR (Art. 35) were set, 5,000,000 EUR in total; after voluntary payment without admission of liability, 4,000,000 EUR became payable.

What organisations can take from it

External accounts such as those of brokers need strong authentication and must only reach the data that is actually required.

Relevance to training and awareness

Securing intermediary and partner accounts

Authority / court
Agencia Española de Protección de Datos (AEPD)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 5 Abs. 1 lit. f, 25, 32, 35 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
20% reduction for voluntary payment (Art. 85 LPACAP), without admission of liability.
Published
13 May 2025

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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.

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5 Dec 2024 Betreiber von Kredit-Websites, UK (anonymisiert)ICO: £200,000 fine for a loan website operator over marketing texts United KingdomMarketing and consent €241,546

The ICO fined a small UK company operating loan websites £200,000 and issued an enforcement notice. According to the ICO, between September 2022 and December 2023, 37,977 complaints were received about marketing messages that it found were sent at the company's instigation without valid consent and in some cases without identifying the sender. Early payment reduces the penalty to £160,000.

Authority / court
Information Commissioner's Office (ICO)
Area of law
Data protection · Marketing and consent
Legal basis
Regulations 22 und 23 PECR; section 55A DPA 1998; section 40 DPA 1998 (Enforcement Notice)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 200,000 GBP, converted at the ECB reference rate of 5 Dec 2024.

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5 Dec 2024 Breathe Services LtdICO: £170,000 fine for Breathe Services over millions of marketing calls with spoofed numbers United KingdomMarketing and consent €205,314

The ICO fined the Bolton-based debt advice company Breathe Services Ltd £170,000 and issued an enforcement notice. The ICO found that in 2022 the company made more than 4.3 million marketing calls to numbers registered with the Telephone Preference Service, presenting over 1,000 different caller numbers to hide its identity. The ICO had searched its premises in 2023.

Authority / court
Information Commissioner's Office (ICO)
Area of law
Data protection · Marketing and consent
Legal basis
Regulations 21 und 24 PECR; section 55A DPA 1998; section 40 DPA 1998 (Enforcement Notice)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 170,000 GBP, converted at the ECB reference rate of 5 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

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2 Dec 2024 JPMorgan Chase Bank, N.A.MAS: SGD 2.4m civil penalty on JPMorgan over excessive bond spreads SingaporeOrganisational requirements €1.7m

Relationship managers at JPMorgan Chase Bank, N.A. misrepresented or incompletely disclosed price components in 24 over-the-counter bond transactions between November 2018 and September 2019, so that clients paid spreads above those agreed (in breach of s 201(c) and (d) SFA, the Securities and Futures Act). The bank admitted liability under s 236C SFA because, lacking adequate processes and controls, it had neither prevented nor detected the misconduct; it allegedly paid the Monetary Authority of Singapore (MAS, Singapore's central bank and financial regulator) a civil penalty of SGD 2.4 million and refunded the overcharged fees to clients. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

A firm that gives relationship managers discretion over pricing must systematically check compliance with agreed terms – otherwise the institution is liable for their misconduct.

Relevance to training and awareness

Accurate and complete disclosure of prices and spreads to clients

Authority / court
Monetary Authority of Singapore (MAS)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
ss 201(c), 201(d), 232 und 236C Securities and Futures Act (SFA)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Culpability
negligent
Published
2 Dec 2024

Original amount 2,400,000 SGD, converted at the ECB reference rate of 2 Dec 2024.

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2 Dec 2024 2147353 Ontario Inc.FINTRAC: CAD 33,000 penalty on 2147353 Ontario Inc. for one violation of anti-money laundering obligations CanadaInternal controls €22,376

According to FINTRAC, 2147353 Ontario Inc. is a money services business based in Mississauga, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 33,000 on the company on 2 December 2024. According to FINTRAC's findings, the company committed one violation of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violation concerned providing documents requested by notice. According to FINTRAC, the case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "FINTRAC imposes an administrative monetary penalty on Cash Shop #27", published 6 February 2025, https://fintrac-canafe.canada.ca/pen/amps/pen-2025-02-06-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 63.1(2); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
6 Feb 2025

Original amount 33,000 CAD, converted at the ECB reference rate of 2 Dec 2024.

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

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28 Nov 2024 WealthBar Financial Services Inc. (CI Direct Investing)CI Direct Investing (WealthBar): CAD 60,000 over KYC and conflict-of-interest failings Canada, British ColumbiaOrganisational requirements €40,623

A 2022 conflicts-of-interest sweep by the Canadian Securities Administrators found that, after the Client Focused Reforms took effect, the online portfolio manager had failed to identify and disclose conflicts arising from referral arrangements with twelve partners, assessed clients referred through four of those partners only for those partners' model portfolios and did not meet its know-your-client obligations because its online questionnaire was incomplete. Under its settlement with the BCSC, WealthBar undertook to pay CAD 60,000; it had previously paid CAD 14,800 in examination costs and retained an independent compliance monitor for one year.

What organisations can take from it

New rules such as the Client Focused Reforms require an active reassessment of existing partnerships, questionnaires and advice processes.

Relevance to training and awareness

Conflicts of interest, suitability and know-your-client in digital wealth management

Authority / court
British Columbia Securities Commission (BCSC), Executive Director (Vergleich)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
National Instrument 31-103, s. 13.2, 13.2.01 (Know your Client), 13.3 (Eignung), 13.4 (Interessenkonflikte); Securities Act (British Columbia), RSBC 1996, c. 418
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Early settlement, cooperation during the examination and the proceedings, no investor complaints; the deficiencies were remedied under the oversight of a compliance monitor.
Published
28 Nov 2024

Original amount 60,000 CAD, converted at the ECB reference rate of 28 Nov 2024.

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27 Nov 2024 Crédit Agricole Vita S.p.A.IVASS fines Crédit Agricole Vita €516,000 over ineffective product governance (POG) ItalyOrganisational requirements €516,000

IVASS (Italian insurance supervisor) imposed a fine of 516,000 EUR on Crédit Agricole Vita S.p.A. under Art. 324-bis of the Private Insurance Code (CAP). Following an on-site inspection, the supervisor found that the product oversight and governance (POG) system was ineffective because of shortcomings in every phase of the process.

What organisations can take from it

Product governance must work in every phase, from defining the target market to ongoing review, or the whole system is deemed ineffective.

Relevance to training and awareness

Product approval and product oversight (POG)

Authority / court
IVASS (Istituto per la Vigilanza sulle Assicurazioni)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 30-decies und Art. 324-bis Abs. 1 und 4 D.Lgs. 209/2005 (CAP); Art. 5–10 IVASS-Verordnung 45/2020
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
31 Dec 2024

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26 Nov 2024 Macquarie Bank Limited, London BranchMacquarie Bank London: 13 million GBP over control failures, more than 400 fictitious trades went undetected United KingdomOrganisational requirements €15.6m

According to the FCA's findings, more than 400 fictitious trades were booked and three key internal controls circumvented on the branch's metals and commodities desk between June 2020 and February 2022, so that losses remained concealed; 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 a fine of around 13 million GBP on the bank.

What organisations can take from it

Close known control weaknesses in trading with a deadline and a responsible owner; otherwise individual misconduct 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

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

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26 Nov 2024 Kiwibank LimitedKiwibank: 1.5 million NZD fine for systemically misapplied customer terms New ZealandMisleading advertising and pricing €835,189

The bank pleaded guilty to 21 charges under the Fair Trading Act because for years it had not provided services to customers on the agreed terms, for example discounts and interest-free periods under package agreements, correctly calculated repayments, the switch to principal repayments after interest-only periods and correct fees. Around 35,000 customers were overcharged a total of 6.8 million NZD; on 26 November 2024 the Auckland District Court imposed a fine of 1.5 million NZD. According to the Commerce Commission (New Zealand's consumer and competition regulator), the causes were errors in electronic systems and a lack of quality assurance checks on whether staff knew and followed the processes.

What organisations can take from it

Agreed terms must be correctly set up in systems and monitored through quality assurance; system errors are no excuse.

Relevance to training and awareness

Correctly applying agreed terms in banking processes

Missing or inadequate training played a role in the decision.

Authority / court
Auckland District Court (Anklage: Commerce Commission)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Fair Trading Act 1986, ss 13(i), 40(1)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The bank had identified and reported the errors itself and is progressively refunding customers 9.2 million NZD.
Published
27 Nov 2024

Original amount 1,500,000 NZD, converted at the ECB reference rate of 26 Nov 2024.

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26 Nov 2024 Carnegie Investment Bank ABCarnegie Investment Bank: SEK 1.3m for a pre-arranged trade in Vertiseit shares SwedenMarket abuse and insider dealing €112,818

Finansinspektionen (FI, Swedish Financial Supervisory Authority) imposed an administrative fine of 1,300,000 SEK on Carnegie Investment Bank by way of a sanction order (sanktionsföreläggande) for market manipulation. On 2 August 2024, Carnegie placed a client buy order for 100,000 shares in Vertiseit AB which, in concert with another party, was executed against a sell order of the same quantity and price placed almost simultaneously (98,202 shares at 43.70 SEK, 87% of daily turnover). The trade was likely to give false or misleading signals as to the supply of, demand for or price of the share.

What organisations can take from it

Trading desks must recognise and stop orders pre-arranged with counterparties as a manipulation risk, even when they are placed on behalf of clients.

Relevance to training and awareness

Recognising manipulative order patterns (pre-arranged matching orders)

Authority / court
Finansinspektionen (FI)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 12 Abs. 1 lit. a Ziff. i und Art. 15 Verordnung (EU) Nr. 596/2014 (MAR); 5 kap. 1 § 2 samt 6 och 19 §§ lagen (2016:1306) med kompletterande bestämmelser till EU:s marknadsmissbruksförordning
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
20 Dec 2024

Original amount 1,300,000 SEK, converted at the ECB reference rate of 26 Nov 2024.

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25 Nov 2024 Barclays plcFCA: £30m fine for Barclays plc over undisclosed Qatari arrangements in 2008 United KingdomDisclosure and reporting obligations €35.9m

The FCA fined Barclays plc £30 million. The FCA found that during its capital raisings in June and October 2008, Barclays entered into advisory agreements with a Qatari investor group whose fees were linked to their participation in the capital raisings. These fees and the link were not disclosed in announcements, prospectuses and a shareholder circular, which in the FCA's view made them misleading. The FCA found failures to take reasonable care over published information and breaches of the requirements for shareholder circulars. In relation to the October 2008 capital raising, it found that Barclays plc had acted recklessly and had not acted with integrity towards its shareholders (Listing Principle 3). Barclays plc had referred the decision notice of 23 September 2022 to the Upper Tribunal but withdrew the reference on 22 November 2024.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
LR 1.3.3R; LR 13.3.1R(3); Listing Principle 3; section 91 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 30,000,000 GBP, converted at the ECB reference rate of 25 Nov 2024.

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25 Nov 2024 Barclays Bank plcFCA: £10m fine for Barclays Bank plc over incomplete 2008 prospectuses United KingdomDisclosure and reporting obligations €12m

The FCA fined Barclays Bank plc £10 million. The FCA found that, in connection with the October 2008 capital raising, the bank issued financial instruments whose prospectuses did not mention an advisory agreement with a Qatari investor group and the related fees, which in its view made them misleading. The FCA found a failure to take reasonable care over published information; a separate decision was issued against the parent Barclays plc. Barclays Bank plc had referred the decision notice of 23 September 2022 to the Upper Tribunal but withdrew the reference on 22 November 2024.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Listing Rule 1.3.3R; section 91 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 10,000,000 GBP, converted at the ECB reference rate of 25 Nov 2024.

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25 Nov 2024 Government Employees Insurance Company (GEICO)GEICO: 5 million USD from NYDFS over cyberattacks on quoting and claims portals USA, NYSecurity measures and risk management €4.76m

From late 2020 onwards, attackers obtained non-public data of New Yorkers, above all driver's licence numbers, in several incidents through publicly accessible web applications of the car insurer GEICO – including the quoting portal, the claims website and an interface. The New York State Department of Financial Services (NYDFS) found breaches of the cybersecurity regulation 23 NYCRR Part 500, including inadequate risk assessments, missing monitoring of user activity and incorrect compliance certifications for 2017 to 2021, and imposed a penalty of 5,000,000 USD. In parallel, GEICO pays a further 4,750,000 USD in a separate settlement with the New York Attorney General. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

After an incident it is not enough to close the one gap – all publicly accessible applications need to be reassessed, especially once the industry has been warned.

Relevance to training and awareness

Security of publicly accessible web applications; responding to industry alerts

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 §§ 500.2(b), 500.3(i) und (k), 500.5, 500.8(a), 500.9(a), 500.14(a), 500.17(b); Strafe nach New York Financial Services Law § 408
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The NYDFS acknowledged the company's cooperation during the investigation and its substantial investment in remediating the shortcomings.
Published
25 Nov 2024

Original amount 5,000,000 USD, converted at the ECB reference rate of 25 Nov 2024.

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25 Nov 2024 KT Bank AGBaFin imposes 30 fines totalling €600,000 on KT Bank for AML and banking law breaches GermanyCustomer due diligence €600,000

BaFin (German Federal Financial Supervisory Authority) imposed 30 fines of 20,000 EUR each, 600,000 EUR in total, on KT Bank AG. Among other things, the bank had not effectively monitored its internal safeguards, had not retained identification records, had not continuously monitored business relationships, had not recorded the names of beneficial owners, had failed to file suspicious activity reports and had granted loans without fully reviewing the financial circumstances under the disclosure requirements. The decision of 25 November 2024 has been final since 20 December 2024.

What organisations can take from it

Many gaps in the customer process, from identification to suspicious activity reporting, are fined individually and add up.

Relevance to training and awareness

Identifying beneficial owners and continuously monitoring business relationships

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 56 Abs. 1 Nr. 3, 7, 20, 21, 30, 33 und 69 GwG; § 56 Abs. 2 Nr. 5 KWG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
23 Jan 2025

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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)
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.

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22 Nov 2024 NOW: Pensions Limited und NOW: Pension Trustee LimitedPensions Regulator: £50,000 each for NOW: Pensions and its trustee over reporting failures United KingdomDisclosure and reporting obligations €120,185

The Determinations Panel of The Pensions Regulator imposed penalties of 50,000 GBP each – the statutory maximum – on NOW: Pensions Limited (scheme funder and strategist) and NOW: Pension Trustee Limited (trustee) of the NOW: Pensions Trust master trust. Both had failed to report three series of undelivered statutory communications to members and potential members – according to TPR more than 80,000 communications about automatic enrolment rights – as significant events, and had failed to report two of them as breaches of law in time. It was the first enforcement action against an authorised master trust for reporting failures.

What organisations can take from it

Anyone who discovers system failures affecting statutory communications must report them to the regulator promptly as an event and as a breach of law – an internal review does not replace the report.

Relevance to training and awareness

Reporting system and process failures to the regulator

Authority / court
The Pensions Regulator (TPR), Determinations Panel
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
s. 10 Pensions Act 1995; s. 16 Pension Schemes Act 2017; s. 70 Pensions Act 2004; reg. 14 Occupational Pension Schemes (Master Trusts) Regulations 2018
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Both firms admitted the breaches in a joint statement; the Panel made no finding of a deliberate attempt to conceal the failures; the penalties were paid in full.
Published
18 Jul 2025

Original amount 100,000 GBP, converted at the ECB reference rate of 22 Nov 2024.

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21 Nov 2024 BlueSnap Payment Services Ireland LimitedCentral Bank of Ireland: BlueSnap commingled customer funds – 324,240 EUR and reprimand IrelandOrganisational requirements €324,240

From January 2021 to December 2022, the payment service provider did not deposit customer funds in the designated safeguarding account but commingled them with other funds, and informed the Central Bank of Ireland late after becoming aware of this. According to the supervisor, the causes were a lack of regulatory awareness and inadequate oversight of the safeguarding processes provided by the group; the fine of 463,200 EUR was reduced by 30% to 324,240 EUR owing to the settlement.

What organisations can take from it

Keep customer funds traceably segregated at all times – if the group performs your safeguarding processes, you remain responsible and must report deviations promptly.

Relevance to training and awareness

Segregation of customer funds and reporting obligations towards the supervisor

Authority / court
Central Bank of Ireland
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
European Union (Payment Services) Regulations 2018, Regulations 17(2) und 27
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
negligent
Mitigating circumstances
30% discount for settlement based on undisputed facts; deficiencies fully remedied.
Published
21 Nov 2024

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21 Nov 2024 Tana Africa Capital Managers (Pty) LtdFSCA: ZAR 2.9m against Tana Africa Capital Managers, upheld by the Appeal Board South AfricaInternal controls €152,404

An inspection showed that the asset manager's risk management and compliance programme was deficient and not effectively implemented, and that client data was not screened against the UN Security Council targeted financial sanctions lists. The FSCA imposed ZAR 2.9m, of which ZAR 1m is conditionally suspended for three years; on 6 November 2024 the FIC Act Appeal Board dismissed the appeal against the amount and held that reliance on an external compliance adviser does not relieve an institution of responsibility. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

A firm that outsources compliance to an external provider remains responsible for meeting its anti-money laundering duties itself, even with just a single client.

Relevance to training and awareness

Sanctions list screening and accountability despite external compliance advice

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 42(1), 42(2) i. V. m. s. 21(1); s. 28A i. V. m. ss. 26A–26C
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
ZAR 1m conditionally suspended for three years.
Published
21 Nov 2024

Original amount 2,900,000 ZAR, converted at the ECB reference rate of 21 Nov 2024.

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14 Nov 2024 American Life Insurance Company (ALICO)OFAC: USD 178,421 settlement with American Life Insurance Company over policies for Iranian government entities USABreaches of sanctions and embargoes €169,392

American Life Insurance Company (ALICO), a Delaware-based US insurer with global group and individual business, is paying USD 178,421 under a settlement with OFAC for apparent violations of the Iran sanctions. According to OFAC's findings, between February 2022 and August 2023 ALICO insured three policyholders in the United Arab Emirates that were owned or controlled by the Government of Iran and therefore blocked, including schools; in total 2,331 premiums and claims worth USD 446,077 were processed. Screening alerts were wrongly closed as false positives. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed; the base penalty was USD 223,038. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "American Life Insurance Company Settles with OFAC for $178,421 Related to Apparent Violations of Iranian Transactions and Sanctions Regulations", 14 November 2024, https://ofac.treasury.gov/media/933596/download?inline; summarised in our own words.

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
Iranian Transactions and Sanctions Regulations, 31 C.F.R. §§ 560.204 (Dienstleistungsexport), 560.211 (gesperrtes Vermögen); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
14 Nov 2024

Original amount 178,421 USD, converted at the ECB reference rate of 14 Nov 2024.

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13 Nov 2024 BNP Paribas Fortis SA/NVBNP Paribas Fortis: €10.4m ECB penalty for inaccurate capital reporting EU levelDisclosure and reporting obligations €10.4m

According to the ECB decision, BNP Paribas Fortis reported, on a consolidated basis, inaccurate own funds requirements and risk-weighted assets for factoring exposures in 31 consecutive quarters from 2014 to 2021, because it used internal models whose material deficiencies it was aware of, and did not inform the supervisors. The ECB classified the breach as intentional and severe and imposed 10,400,000 EUR.

What organisations can take from it

Known model deficiencies must be disclosed to the supervisor rather than continuing to report on the basis of flawed results.

Relevance to training and awareness

Disclosure of known model deficiencies to the supervisor

Authority / court
Europäische Zentralbank (EZB), Bankenaufsicht
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 430 Abs. 1 Buchst. a VO (EU) Nr. 575/2013 (CRR), zuvor Art. 99 Abs. 1 CRR; Art. 18 Abs. 1 VO (EU) Nr. 1024/2013
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Published
20 Dec 2024

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12 Nov 2024 Metro Bank PlcFCA: £16.7m fine for Metro Bank over gaps in transaction monitoring United KingdomInternal controls €20.1m

The FCA fined Metro Bank Plc £16,675,200. The FCA found that between June 2016 and December 2020 a data error meant that more than 60 million transactions worth over £51 billion were not fed into the bank's automated anti-money laundering monitoring system. For a long time the bank did not check whether data reached the system completely. The fine includes a 30% settlement discount.

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

Original amount 16,675,200 GBP, converted at the ECB reference rate of 12 Nov 2024.

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12 Nov 2024 Saxo Bank A/S (Rechtsnachfolgerin der BinckBank N.V.)AFM: €1.6m fines for Saxo Bank over failings in the BinckBank migration NetherlandsOrganisational requirements €1.6m

On 12 November 2024 the Autoriteit Financiële Markten (AFM, Dutch Authority for the Financial Markets) imposed three fines totalling 1.6 million EUR on Saxo Bank A/S as legal successor to BinckBank N.V. While BinckBank’s customers were being moved onto Saxo’s systems, BinckBank kept its securities records so inaccurately that the ownership of securities and funds could no longer be established with certainty (500,000 EUR), controlled critical processes protecting client assets inadequately (500,000 EUR) and did not treat customers with due care, for example through delayed transfers and transactions, excessive charges and a customer service that was hard to reach (600,000 EUR). Saxo did not object; the fines have been final since 25 December 2024.

What organisations can take from it

In IT and customer migrations after an acquisition, safeguarding of client assets, controls and customer service must be explicitly secured.

Relevance to training and awareness

Safeguarding client assets and customer protection in IT and customer migrations

Authority / court
Autoriteit Financiële Markten (AFM)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 165 Abs. 1 Buchst. a, b und f Besluit Gedragstoezicht financiële ondernemingen Wft (BGfo); Art. 4:90 Abs. 1 Wet op het financieel toezicht (Wft)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
7 Jan 2025

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12 Nov 2024 Hamburger Dienstleister aus dem Forderungsmanagement (anonymisiert)HmbBfDI: €900,000 fine on debt collector for failing to delete debtor data GermanyData protection €900,000

During a sector-wide audit of major debt collection firms, the HmbBfDI (Hamburg data protection authority) found on site that a Hamburg service provider had kept a six-figure number of records on debtors without a legal basis until mid-November 2023, in some cases five years beyond the statutory retention period. The company admitted the infringement and accepted the 900,000 EUR fine; its cooperation in dealing with the matter was taken into account.

What organisations can take from it

A deletion policy with fixed retention periods must be in place before data is collected and must actually be applied in the database.

Relevance to training and awareness

Deletion policy and retention periods

Authority / court
Hamburgischer Beauftragter für Datenschutz und Informationsfreiheit (HmbBfDI)
Area of law
Data protection
Legal basis
Art. 5 Abs. 1 lit. a, Art. 6 Abs. 1 DSGVO
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Infringement admitted, fine accepted, professional cooperation in remedying the matter.
Published
12 Nov 2024

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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.

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8 Nov 2024 Fubon Bank (Hong Kong) LimitedHKMA: HKD 4m fine for Fubon Bank (Hong Kong) over transaction monitoring gaps Hong KongInternal controls €477,640

The HKMA imposed a pecuniary penalty of HKD 4 million on Fubon Bank (Hong Kong) because, between April 2019 and July 2022, the bank lacked effective procedures for changes to its transaction monitoring: data transfer from the core banking system was poorly controlled, acceptance tests were ineffective, and there were no procedures for following up a sharp fall in alerts from June 2019 or for regularly reviewing the scope of monitoring. Transactions of around 64,000 customers were not properly scrutinised, and for around 1,500 of them no trigger event review took place after dormant business relationships were reactivated.

What organisations can take from it

A sudden fall in monitoring alerts is itself a warning sign and must be investigated after every system change.

Relevance to training and awareness

Change management and plausibility checks in transaction monitoring

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 19(3) und 5(1) Schedule 2 AMLO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Self-report, cooperation, remediation of the deficiencies and no previous disciplinary record.
Published
8 Nov 2024

Original amount 4,000,000 HKD, converted at the ECB reference rate of 8 Nov 2024.

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6 Nov 2024 Waystone Fund Management (IE) LimitedCentral Bank: €393,512 fine against Waystone for deficient oversight of a fund's investment manager IrelandOrganisational requirements €393,512

As manager of an alternative investment fund, the company carried out little due diligence on the appointed investment manager, which in 2018/2019 invested €17.7m in hard-to-value loan notes; when the fund was suspended in August 2020, €10.2m remained outstanding. The Central Bank found breaches including in due diligence, conflicts of interest, oversight of delegates, risk management and valuation and, by settlement, imposed a reprimand and €393,512 (€562,160 less 30%), confirmed by the High Court on 31 March 2025.

What organisations can take from it

Anyone who delegates investment decisions remains responsible and must continuously check the delegate's experience and investments, even with long-standing business partners.

Authority / court
Central Bank of Ireland
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
European Union (Alternative Investment Fund Managers) Regulations 2013 (S.I. No. 257 of 2013); s. 33BC Central Bank Act 1942
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Settlement under the undisputed facts procedure with a 30% discount; breaches admitted; investors recovered their investment in the loan notes through a settlement.
Published
8 Nov 2024

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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 a fine of 90,000 EUR on the bank.

What organisations can take from it

Policies for impairments and provisions under IFRS 9 must be documented and kept aligned with the EBA guidelines.

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
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5 Nov 2024 Exchange Bank of CanadaFINTRAC: penalty on Exchange Bank of Canada reduced to CAD 1,027,975 on appeal CanadaSuspicious activity reports €679,518

According to FINTRAC, Exchange Bank of Canada is a bank based in Toronto, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 2,457,750 on the company on 5 November 2024. According to FINTRAC's findings, made during a compliance examination, the company committed 3 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, ongoing monitoring of business relationships and large cash transaction reporting. Specifically, FINTRAC found five missing suspicious transaction reports in 26 case files reviewed, eight cases without the required ongoing monitoring and three misclassified and therefore unreported cash transactions; the compliance programme had not been adequate for the bank's business model and global reach. The bank filed an appeal; according to FINTRAC, the Federal Court confirmed the violations on 18 December 2025 but varied the penalty to CAD 1,027,975. The case is closed. Source: FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), "Administrative monetary penalty on Exchange Bank of Canada", published 11 December 2024, https://fintrac-canafe.canada.ca/pen/amps/pen-2024-12-11-eng; summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9(1); PCMLTF Regulations 7(1)(a), 123.1, 156(1)(c), Schedule 1; PCMLTF Suspicious Transaction Reporting Regulations s. 9(1); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
reduced
Sector
Financial services and insurance
Published
11 Dec 2024

Original amount 1,027,975 CAD, converted at the ECB reference rate of 5 Nov 2024.

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

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5 Nov 2024 Edmond de Rothschild Assurances et Conseils (Europe) S.A.Edmond de Rothschild Assurances et Conseils (Europe): EUR 61,000 for AML failings LuxembourgInternal controls €61,000

The Commissariat aux Assurances (CAA, Luxembourg insurance supervisor) fined the insurance brokerage EUR 61,000. A 2021 inspection found, among other things, an inadequate outsourcing contract with the parent company, an incomplete overall risk assessment, gaps on beneficial owners, source of funds and PEPs, a screening tool whose configuration could not be explained and missing annual reports by the compliance officer. The company was also unable to give access to the materials of its internal anti-money laundering training.

What organisations can take from it

Training only counts if its content is documented and can be shown to the supervisor; outsourced due diligence needs a precise contract.

Relevance to training and awareness

Demonstrable anti-money laundering training and outsourcing of due diligence

Missing or inadequate training played a role in the decision.

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 2-1(2), 8-4 und 8-5 Loi modifiée du 12 novembre 2004 (LBC/FT); Règlement grand-ducal du 1er février 2010; 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, with timely replies.
Published
15 Jan 2025

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

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4 Nov 2024 Money Services Business aus Toronto, Ontario (anonymisiert)FINTRAC: CAD 249,480.50 penalty on money services business from Toronto for 6 violations of anti-money laundering obligations CanadaCustomer due diligence €164,619

According to FINTRAC, the company concerned is a money services business based in Toronto, Ontario; its name is not given here. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 249,480.50 on the company on 4 November 2024. According to FINTRAC's findings, made during a compliance examination in 2023, the company committed 6 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, compliance with a ministerial directive, record keeping and money services business registration requirements. Specifically, contrary to the ministerial directive on Iran, the company failed to report 44 transactions originating from Iran, recorded neither the exchange rate nor its source for these foreign exchange transactions and provided registration details that did not reflect its actual activities. According to FINTRAC, the company has appealed the decision to the Federal Court. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
PCMLTFA s. 9.6(1), 11.43; PCMLTF Regulations 36(i), 156(1)(b), 156(1)(c); PCMLTF Registration Regulations s. 4(a), 4(b), 5; Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
13 May 2025

Original amount 249,480.5 CAD, converted at the ECB reference rate of 4 Nov 2024.

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

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30 Oct 2024 Deutsche Bank, S.A.E.CNMV: €10m fine and advisory ban for Deutsche Bank SAE on FX derivatives SpainOrganisational requirements €10m

The Comisión Nacional del Mercado de Valores (CNMV, Spanish securities market supervisor) imposed two fines of 5,000,000 EUR each, totalling 10,000,000 EUR, on Deutsche Bank SAE because from 2018 to March 2021 the bank advised Spanish clients on complex FX derivatives such as Target Profit Forwards and Pivot TPF without complying with its information and suitability obligations and without acting in the clients' best interests. In addition, it was barred for one year from advising on complex OTC FX derivatives in which the client sells options. The decision is not final.

What organisations can take from it

When advising on complex derivatives, suitability assessments, risk disclosure and acting in the client's interest must be fully documented; otherwise activity bans may follow in addition to fines.

Relevance to training and awareness

Investment advice and suitability assessments for complex derivatives

Authority / court
Comisión Nacional del Mercado de Valores (CNMV)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 284.1 und Art. 283.12 i. V. m. Art. 208 bis 211 und 208 ter Texto refundido de la Ley del Mercado de Valores (Real Decreto Legislativo 4/2015); Delegierte Verordnung (EU) 2017/565; Circular CNMV 3/2013
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
10 Feb 2025

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

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30 Oct 2024 野村證券株式会社 (Nomura Securities Co., Ltd.)Nomura Securities: 21.76 million JPY for layering in Japanese government bond futures JapanMarket abuse and insider dealing €131,155

A person engaged in the firm’s proprietary trading had, on 9 March 2021, repeatedly placed several layered orders in the order book for the long-term JGB future (March 2021 contract) on the Osaka Exchange to create a false impression of active trading, and then bought lower or sold higher. After administrative proceedings were opened, Nomura admitted the facts and the amount; an administrative monetary penalty (kachōkin) of 21,760,000 JPY was imposed, made up of 6,940,000 JPY for the matched volume and 14,820,000 JPY for the excess purchases.

What organisations can take from it

Trade surveillance must detect layering patterns in proprietary trading, including in bond futures and not only in equities.

Relevance to training and awareness

Spoofing and layering in proprietary trading

Authority / court
Financial Services Agency (FSA, 金融庁) auf Empfehlung der Securities and Exchange Surveillance Commission (SESC, 証券取引等監視委員会)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Financial Instruments and Exchange Act (FIEA, 金融商品取引法) Art. 174-2 Abs. 1 und 8, Art. 159 Abs. 2 Nr. 1; FIEA Enforcement Order Art. 33-13 Nr. 2; Art. 185-7 Abs. 1
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Published
31 Oct 2024

Original amount 21,760,000 JPY, converted at the ECB reference rate of 30 Oct 2024.

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

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29 Oct 2024 Raiffeisenbank Austria d.d.Croatia: 142,483 EUR fine for Raiffeisenbank Austria over anti-money-laundering breaches CroatiaCustomer due diligence €142,483

On the basis of an agreement with the Hrvatska narodna banka (HNB, Croatian National Bank), the Financijski inspektorat (Financial Inspectorate) issued a penalty decision against Raiffeisenbank Austria d.d.: for several customers the bank had failed to take risk factors into account in due diligence, did not monitor business relationships on an ongoing basis, did not properly establish beneficial owners, and did not analyse unusual cash and transfer patterns or report them to the financial intelligence unit. The bank received fines totalling EUR 142,482.94.

What organisations can take from it

Transaction patterns that do not match declared income must be analysed, documented and reported.

Relevance to training and awareness

Recognising and reporting unusual cash patterns

Authority / court
Ministarstvo financija, Financijski inspektorat (Veröffentlichung durch die Hrvatska narodna banka)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 150 Abs. 1 Nr. 8, 11, 23, 26, 43, 44 Zakon o sprječavanju pranja novca i financiranja terorizma (i. V. m. Art. 14, 15, 30, 37, 53)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
The proceedings were concluded by an agreement between the parties (Art. 109.e of the Misdemeanours Act).
Liability of senior managers
Measures against individuals are not reported here.

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23 Oct 2024 Goldman Sachs Bank USACFPB: Goldman Sachs Bank USA pays 64.8 million USD over Apple Card failures USAConsumer protection and online retail €41.8m

According to the CFPB, as issuing bank of the Apple Card Goldman failed to acknowledge and resolve transaction disputes on time, reported disputed amounts to credit bureaus prematurely and investigated disputes inadequately (Truth in Lending Act, Regulation Z); the card was launched although the board had been warned shortly beforehand that the dispute system was not fully ready. The bank also gave the misleading impression that device purchases would automatically be converted into interest-free instalments; the order requires 19.8 million USD in redress and a fine of 45 million USD. The authority allegedly made the findings set out here; this account is not based on a final judgment. The amount field records only the civil monetary penalty.

What organisations can take from it

A product must not launch while legally required dispute processes are not working – not even under pressure from a partner.

Relevance to training and awareness

Launching products only after complaint and dispute processes have been signed off

Authority / court
Consumer Financial Protection Bureau (CFPB)
Area of law
Consumer protection and online retail
Legal basis
Truth in Lending Act und Regulation Z; Consumer Financial Protection Act of 2010, §§ 1031, 1036
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
The CFPB stresses that the board had been warned four days before the card's launch that the dispute system was not ready.
Published
23 Oct 2024

Original amount 45,000,000 USD, converted at the ECB reference rate of 23 Oct 2024.

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

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21 Oct 2024 Volkswagen Financial Services (UK) LimitedFCA: £5.4m fine for Volkswagen Financial Services (UK) over treatment of customers in financial difficulty United KingdomConsumer protection and online retail €6.48m

The FCA fined the motor finance provider Volkswagen Financial Services (UK) Limited £5,397,600. The FCA found that between January 2017 and July 2023 the company did not treat customers in financial difficulty fairly, did not adequately consider their individual circumstances and in some cases repossessed cars that customers relied on for work; complaints were also not properly identified. At least 109,589 customers suffered or were at risk of detriment. The fine includes a 30% discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Consumer protection and online retail
Legal basis
FCA Principles 3, 6 und 7; CONC 7.2.1R, 7.3.4R, 7.3.9R, 7.3.14R(1); DISP 1.3.1R; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 5,397,600 GBP, converted at the ECB reference rate of 21 Oct 2024.

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

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15 Oct 2024 a Czech bankČNB: CZK 9.5 million fine on a bank over deficient AML and sanctions controls CzechiaInternal controlsanonymised €376,357

By way of a penalty order, the Czech National Bank (ČNB) fined a Czech bank CZK 9,500,000. In 2021 the bank lacked adequate internal procedures for, among other things, screening against sanctions lists, customer risk profiles, due diligence on credit and financial institutions as customers, transaction monitoring (for example whitelisting, deposit machines and politically exposed persons) and lending, and between 2020 and 2022 it failed to examine adequately the ownership structure, risk rating and transactions of a single corporate customer. In addition, from 2019 to May 2022 it did not train certain staff in anti-money laundering within the twelve-month deadline and, by means of an internal list, excluded members of its supervisory body and internal audit from this training altogether.

What organisations can take from it

Sanctions screening and transaction monitoring must capture every party at system level, including pledgors, owners and counterparty banks, otherwise gaps remain despite written policies.

Relevance to training and awareness

Sanctions list screening, transaction monitoring and AML training in banking operations

Missing or inadequate training played a role in the decision.

Authority / court
Česká národní banka (ČNB)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
§ 9 Abs. 1 lit. c, § 21 Abs. 1, § 23 Abs. 1 und 2, § 44 Abs. 1 lit. b und Abs. 2, § 48 Abs. 1 und 6 Zákon č. 253/2008 Sb. (AML-Gesetz)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 9,500,000 CZK, converted at the ECB reference rate of 15 Oct 2024.

Checked against the official source on 28 Sep 2026 · Version 2 · Company name anonymised since 15 Oct 2026 · Direct link

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10 Oct 2024 a major Canadian bankFederal Reserve: 123.5 million USD against a major Canadian bank over AML oversight failure USAInternal controlsanonymised €113m

The Board of Governors of the Federal Reserve System imposed 123.5 million USD on a major Canadian bank as 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. The bank 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 28 Sep 2026 · Version 3 · Company name anonymised since 10 Oct 2026 · Direct link

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9 Oct 2024 a UK retail bankFCA: £10.9m fine for UK retail bank over treatment of customers in arrears United KingdomConsumer protection and online retailanonymised €13m

The FCA fined a UK retail bank £10,910,500. The FCA found that between June 2014 and March 2020 the bank treated some retail customers in arrears or financial difficulty on mortgages, loans, credit cards or overdrafts unfairly, including potentially vulnerable customers. 232,849 customers suffered or were at risk of loss; the company paid around £99.9 million in redress. This case is separate from the fine against the company over its 2018 IT migration. The fine includes a 30% discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Consumer protection and online retail
Legal basis
FCA Principles 3 und 6; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 10,910,500 GBP, converted at the ECB reference rate of 9 Oct 2024.

Checked against the official source on 28 Sep 2026 · Version 3 · Company name anonymised since 9 Oct 2026 · Direct link

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9 Oct 2024 a UK securities trading firmCONSOB: EUR 260,000 fine on a securities trading firm for uncovered short selling, profit confiscated ItalyMarket abuse and insider dealinganonymised €260,000

The Italian securities regulator CONSOB imposed a fine of EUR 260,000 on a UK securities trading firm and additionally ordered the confiscation of the profit made, EUR 248,203. On 12 and 13 July 2022, during the capital increase of a listed Italian company, the firm had short sold 299,653 shares worth EUR 551,742 without having covered them (EUR 230,000 for the breach of Art. 12 of the Short Selling Regulation) and had not notified the resulting net short position to CONSOB or the public (an increase of EUR 30,000).

What organisations can take from it

Short selling without prior cover and without notifying the net position costs not only a fine but also the entire profit.

Relevance to training and awareness

Uncovered short selling and notification of net short positions

Authority / court
CONSOB (Commissione Nazionale per le Società e la Borsa)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 5, 6, 9 und 12 Verordnung (EU) 236/2012 (Leerverkaufsverordnung); Art. 193-ter Abs. 1, 2 und 4 D.Lgs. 58/1998 (TUF)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
intentional
Published
7 Nov 2024

Checked against the official source on 28 Sep 2026 · Version 2 · Company name anonymised since 9 Oct 2026 · Direct link

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1 Oct 2024 a US swap trading platformSwap trading platform: 875,000 USD because emergency and security tests were not brought before the board USACritical infrastructureanonymised €789,284

A US 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 28 Sep 2026 · Version 3 · Company name anonymised since 1 Oct 2026 · Direct link

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30 Sep 2024 a registered swap dealerCFTC: USD 4 million for misreporting more than five million swaps USADisclosure and reporting obligationsanonymised €3.57m

The CFTC fined the registered swap dealer 4 million USD. From 2018 to 2023 the firm reported more than five million swap transactions incorrectly or late, among other things because of a duplicate swap identifier, incorrect primary economic terms and time stamps, and errors in continuation data reporting. The firm admitted the facts; the fine was lower because of substantial cooperation and remediation. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Derivatives reporting chains need ongoing data quality controls; firms that report errors themselves can significantly reduce the sanction.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Sections 2(a)(13) und 4r(a)(3) Commodity Exchange Act; CFTC Regulations 43.3 und 45.3–45.4
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
1 Oct 2024

Original amount 4,000,000 USD, converted at the ECB reference rate of 30 Sep 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 30 Sep 2026 · Direct link

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27 Sep 2024 a UK digital bankFCA: £29m fine for digital bank over financial crime controls United KingdomCustomer due diligenceanonymised €34.7m

The FCA fined a UK digital bank £28,959,426. The FCA found that the fast-growing bank's controls against money laundering and sanctions breaches did not keep pace with its growth. Although the bank agreed with the FCA in 2021 not to open accounts for high-risk customers, it opened 54,359 accounts for 49,183 such customers. In addition, screening of customers and payments against sanctions lists was inadequate between December 2019 and November 2023. The fine includes a 30% discount.

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

Original amount 28,959,426 GBP, converted at the ECB reference rate of 27 Sep 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 27 Sep 2026 · Direct link

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27 Sep 2024 a South African life insurerLife insurer: ZAR 15.9m for breaches of anti-money laundering duties South AfricaCustomer due diligenceanonymised €832,060

A 2020 inspection found that the life insurer had not carried out adequate customer due diligence on sampled relationships (including address verification and identification of beneficial owners), had reported cash transactions above the threshold and suspicious transactions late, and had not adequately developed and implemented its risk management and compliance programme. Four cautions and penalties totalling 15.9 million ZAR were imposed, of which 5.9 million ZAR is conditionally suspended for 36 months from 23 July 2024.

What organisations can take from it

Life insurers, too, must risk-rate clients before onboarding and meet the reporting deadlines towards the financial intelligence unit.

Relevance to training and awareness

Customer due diligence and reporting deadlines in insurance distribution

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Sections 21, 21A–21H, 28 (i. V. m. Regulations 22B, 22C, 24(4)), 29 (i. V. m. Regulation 24(3)) und 42 Financial Intelligence Centre Act 38 of 2001
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation throughout the process and remedial action; 5.9 million ZAR suspended for 36 months.
Published
27 Sep 2024

Original amount 15,900,000 ZAR, converted at the ECB reference rate of 27 Sep 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 27 Sep 2026 · Direct link

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26 Sep 2024 a US asset managerSEC: US asset manager pays 500,000 US dollars over NDAs and severance agreement USARetaliation against whistleblowersanonymised €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.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 26 Sep 2026 · Direct link

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26 Sep 2024 a Japanese crypto exchangeJapanese crypto exchange: order after outflow of 4,502.9 BTC over poor key management JapanSecurity measures and risk managementanonymised Order

After customer holdings of 4,502.9 BTC were transferred out of the crypto exchange’s custody without authorisation on 31 May 2024, the inspection found serious failings: no board member responsible for IT, security powers concentrated in a few people, signing with private keys without a second check, keys managed in one bundle rather than distributed, an internal audit function that was not independent and no decisions on retaining logs to preserve evidence. The business improvement order under Art. 63-16 of the Payment Services Act required a root-cause analysis, continued customer protection, new management of system risks and clarification of management responsibility before the suspended trading could resume.

What organisations can take from it

Private keys for customer funds must be under dual control and held in distributed custody; no one should be able to sign transfers alone.

Relevance to training and awareness

Key management and the four-eyes principle in crypto custody

Authority / court
Regionales Finanzbüro (Local Finance Bureau), Aufsicht im Auftrag der Financial Services Agency (FSA, 金融庁)
Area of law
Information security and cyber · Security measures and risk management
Legal basis
Payment Services Act (資金決済に関する法律) Art. 63-16
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
The authority criticised the president and board for treating system risk management as a low priority and not discussing the risk of outflows; the order required management responsibility to be clarified.
Published
26 Sep 2024

Checked against the official source on 14 Oct 2026 · Company name anonymised since 26 Sep 2026 · Direct link

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25 Sep 2024 an Australian fund managerAustralian fund manager: 12.9 million AUD for misleading ESG screens AustraliaMisleading environmental and sustainability claimsanonymised €7.93m

The Federal Court of Australia, on application by the Australian Securities and Investments Commission (ASIC, Australia's corporate, markets and financial services regulator), imposed a penalty of 12.9 million AUD because the fund manager claimed in product documents, on its website, in a media release and in online appearances that an ethically oriented global bond index fund excluded issuers with significant business activities in, among others, fossil fuels. According to the court, around 74% of the fund's securities by market value had in fact not been screened against the ESG criteria; the court had already found liability on 28 March 2024.

What organisations can take from it

ESG exclusions may only be advertised if they are actually applied to, and checked against, the entire portfolio.

Relevance to training and awareness

ESG screening and product claims: aligning marketing with the actual index methodology

Authority / court
Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
ASIC Act 2001 (Cth) ss 12DF(1), 12DB(1)(a) und (e); Geldbuße nach ss 12GBA/12GBB
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The company had identified the matter itself, reported it to ASIC and cooperated fully; the court applied a 25% discount for this.
Published
25 Sep 2024

Original amount 12,900,000 AUD, converted at the ECB reference rate of 25 Sep 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 25 Sep 2026 · Direct link

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25 Sep 2024 a Czech insurerČNB: CZK 5m fine for an insurer – foreigners' policies renewed against customers' needs CzechiaConsumer protection and online retailanonymised €199,021

The ČNB (Czech National Bank) fined an insurer 5,000,000 CZK under the insurance distribution act. Between August 2021 and March 2022 the insurer renewed travel health insurance for foreigners in 632 cases although these policies could no longer serve customers to meet residence requirements, because during that period only one other insurer was allowed to offer such insurance for that purpose. The ČNB Bank Board upheld the decision on 30 January 2025.

What organisations can take from it

When the legal framework for a product changes, sales and renewal processes must immediately check whether it still serves the customer's purpose.

Relevance to training and awareness

Demands-and-needs based distribution in the customer's best interest

Authority / court
Česká národní banka (ČNB)
Area of law
Consumer protection and online retail
Legal basis
§ 72 Abs. 1, § 114 Abs. 1 lit. f und Abs. 2 lit. a Zákon č. 170/2018 Sb. (ZDPZ, Fassung bis 28. 5. 2022)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 5,000,000 CZK, converted at the ECB reference rate of 25 Sep 2024.

Checked against the official source on 28 Sep 2026 · Company name anonymised since 25 Sep 2026 · Direct link

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19 Sep 2024 a UK debt advice companyICO: £30,000 fine for debt advice firm over marketing texts United KingdomMarketing and consentanonymised €35,734

The ICO fined the company £30,000 and issued an enforcement notice. The ICO found that between April and August 2023 the company sent around 130,000 unsolicited marketing texts, leading to more than 4,000 reports to the 7726 spam reporting service. Early payment reduces the penalty to £24,000.

Authority / court
Information Commissioner's Office (ICO)
Area of law
Data protection · Marketing and consent
Legal basis
Regulation 22 PECR; section 55A DPA 1998; section 40 DPA 1998 (Enforcement Notice)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 30,000 GBP, converted at the ECB reference rate of 19 Sep 2024.

Sources

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 19 Sep 2026 · Direct link

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18 Sep 2024 a Danish major bankPNF: Danish major bank pays €6.33m over laundering the proceeds of tax fraud FranceMoney laundering and terrorist financinganonymised €6.33m

The bank undertook, in a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement) with the Parquet national financier (PNF, French national financial prosecutor), to pay a public interest fine of 6,028,799 EUR and 300,000 EUR in damages to the French State, allegedly 6,328,799 EUR in total. The allegation concerned money laundering linked to organised tax fraud. Measures against individuals are not set out here. Validated on 18 September 2024.

What organisations can take from it

Banks face criminal liability when proceeds of organised tax fraud flow through their accounts; customer due diligence and transaction monitoring must capture this.

Relevance to training and awareness

Money laundering risks from customers' tax fraud schemes

Authority / court
Parquet national financier (PNF); gerichtliche Validierung
Area of law
Money laundering and terrorist financing
Legal basis
Art. 41-1-2 Code de procédure pénale (blanchiment de fraude fiscale en bande organisée)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
18 Sep 2024

Checked against the official source on 14 Oct 2026 · Version 2 · Company name anonymised since 18 Sep 2026 · Direct link

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17 Sep 2024 a Swiss private bankFINMA: private bank seriously breached AML duties, CHF 12.7 million confiscated SwitzerlandCustomer due diligenceanonymised €13.5m

The Eidgenössische Finanzmarktaufsicht (FINMA, Swiss Financial Market Supervisory Authority) found that the bank, despite warnings, inadequately checked and documented beneficial ownership and the background of transactions in business relationships with complex structures possibly attributable to a now-deceased businessman accused of tax evasion, which at times held up to USD 1.7 billion. FINMA confiscated CHF 12.7 million of unlawfully earned profits, prohibited the bank from taking on new clients with increased money-laundering risks until compliance is restored, ordered a review of all client relationships and of higher-risk transactions from 2018 to 2022, and appointed an audit agent. The ruling issued in June 2023 has been final since August 2023.

What organisations can take from it

Since aggravated tax offences count as predicate offences, banks must investigate tax-risk warning signs just like other money-laundering risks.

Relevance to training and awareness

Aggravated tax offences as a predicate offence to money laundering; duty to investigate

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Finanzmarktaufsichtsrecht: Geldwäschereiprävention, angemessene Organisation und Risikomanagement (Einziehung zugunsten der Staatskasse)
Action
Disgorgement of profits
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The bank cooperated in the proceedings and took its own organisational, operational and personnel measures during the proceedings.
Liability of senior managers
FINMA opened three enforcement proceedings against individuals.
Published
17 Sep 2024

Original amount 12,700,000 CHF, converted at the ECB reference rate of 17 Sep 2024.

Sources

Checked against the official source on 2 Oct 2026 · Company name anonymised since 17 Sep 2026 · Direct link

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16 Sep 2024 a foreign bank operating in the UAECBUAE fines a foreign bank AED 5m United Arab EmiratesCapital markets and financial supervisionanonymised €1.22m

The Central Bank of the UAE (CBUAE) fined an unnamed bank operating in the UAE AED 5 million under Articles 89 and 137 of the central bank law (Federal Decree Law No. 14 of 2018) and Article 14 of the anti-money laundering law (Federal Decree Law No. 20 of 2018). The bank was also required to present the measure to the board of directors of its overseas headquarters; the release does not state what the breaches were.

What organisations can take from it

Supervisory action against a bank's local operation can reach the board of its overseas headquarters – local compliance therefore belongs in group governance.

Relevance to training and awareness

Involving group leadership in supervisory measures

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Capital markets and financial supervision
Legal basis
Art. 89 und 137 Federal Decree Law No. (14) of 2018 (Zentralbankgesetz); Art. 14 Federal Decree Law No. (20) of 2018 (AML/CFT)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
16 Sep 2024

Original amount 5,000,000 AED, converted at the ECB reference rate of 16 Sep 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 16 Sep 2026 · Direct link

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9 Sep 2024 a US financial services companySEC: US financial services company pays 312,000 US dollars over waivers of whistleblower awards USARetaliation against whistleblowersanonymised €282,532

Between May 2019 and September 2023, the company 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, the company 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.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 9 Sep 2026 · Direct link

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6 Sep 2024 a Brazilian bankBrazilian bank: fine over prohibited correspondent fees, reduced to BRL 2.35m BrazilCapital markets and financial supervisionanonymised €380,244

The BCB (central bank) sanctions committee COPAS imposed a fine of BRL 2,940,000.00 on a Brazilian bank because from February 2015 to March 2020 the bank added the fee for its banking correspondent's platform to the loan amount of customers in 87,906 credit agreements (BRL 52,218,335.66 in total), although Resolução CMN 3.954/2011 prohibited such additional charges. The Council of Appeals of the National Financial System (CRSFN) reduced the fine to BRL 2,352,000.00 on 12 August 2025; it has been paid.

What organisations can take from it

Fees of distribution partners must not be passed on covertly to customers' loans where the supervisor prohibits this.

Relevance to training and awareness

Prohibited charges on loans sold through distribution partners

Authority / court
Banco Central do Brasil (Comitê de Decisão de Processo Administrativo Sancionador – COPAS)
Area of law
Capital markets and financial supervision
Legal basis
Lei 13.506/2017, Art. 3 XVII q, Art. 5 II; Resolução CMN 3.954/2011, Art. 17 (heute Resolução CMN 4.935/2021, Art. 11 I)
Action
Fine
Status of proceedings
reduced
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
The assessment took into account that there were no final prior convictions in sanction proceedings.

Original amount 2,352,000 BRL, converted at the ECB reference rate of 6 Sep 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 6 Sep 2026 · Direct link

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4 Sep 2024 a Belgian bankBelgian bank: €1m for offering savings certificates without a prospectus BelgiumDisclosure and reporting obligationsanonymised €1m

The bank continued to offer its savings certificates to the public after the volume raised over twelve months had reached, by 4 April 2023 at the latest, the 75 million EUR threshold for the exemption from the prospectus requirement, without publishing a prospectus, and disseminated advertising for them without prior approval by the FSMA (Belgian Financial Services and Markets Authority). By the time sales stopped on 1 June 2023, it had raised 289,218,514 EUR in this way. Under the settlement the bank pays allegedly 1,000,000 EUR and undertakes to strengthen its management committee with a member with solid legal expertise; the FSMA pointed out that the bank had already concluded a settlement of 300,000 EUR in 2021 over advertising not approved in advance.

What organisations can take from it

Prospectus exemptions tied to volume thresholds must be monitored continuously; if the threshold is about to be exceeded, sales must be adjusted immediately.

Relevance to training and awareness

Prospectus requirement and thresholds for continuous issuance by banks

Authority / court
Autorité des services et marchés financiers / Autoriteit voor Financiële Diensten en Markten (FSMA) – Comité de direction (règlement transactionnel)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 1 Abs. 4 lit. j und Art. 3 Abs. 1 Verordnung (EU) 2017/1129 (Prospektverordnung); Art. 24 § 1 und Art. 27 Gesetz vom 11. Juli 2018 über öffentliche Angebote von Anlageinstrumenten; Art. 71 § 3 Gesetz vom 2. August 2002
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
The bank stopped sales with effect from 1 June 2023, subsequently submitted a draft prospectus to the FSMA and adopted organisational measures to strengthen its legal risk culture.
Liability of senior managers
As part of the settlement, the bank undertook to add a member with solid legal expertise to its management committee and, until then, to set up an advisory executive committee including such a member.
Sources

Checked against the official source on 7 Oct 2026 · Version 2 · Company name anonymised since 4 Sep 2026 · Direct link

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4 Sep 2024 three US financial advisory firmsSEC: Three US financial advisory firms pay 240,000 US dollars over reporting prohibitions USARetaliation against whistleblowersanonymised €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 (the asset management company), 70,000 (the financial planning company) and 10,000 US dollars (the third firm, a wealth manager).

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.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 4 Sep 2026 · Direct link

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30 Aug 2024 a Hong Kong e-wallet providerE-wallet provider (Hong Kong): HKD 875,000 penalty for customer due diligence gaps Hong KongCustomer due diligenceanonymised €101,209

The e-wallet provider, a stored value facility licensee, must pay a pecuniary penalty of 875,000 HKD. From August 2016 to October 2021 it lacked adequate control systems to repeat customer due diligence upon trigger events and to apply enhanced due diligence in situations presenting a high risk of money laundering and terrorist financing. The company had self-reported the failings.

What organisations can take from it

Wallet providers must reliably turn trigger events into a fresh customer review and treat high-risk cases separately.

Relevance to training and awareness

Customer due diligence for e-wallets: trigger events and high-risk cases

Authority / court
Hong Kong Monetary Authority (HKMA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
ss. 8Q, 33Q(2)(a) PSSVFO (Cap. 584); Schedule 3 Part 2 s. 6(2)(b) PSSVFO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Self-report, remedial measures, no previous disciplinary record, cooperation.
Published
30 Aug 2024

Original amount 875,000 HKD, converted at the ECB reference rate of 30 Aug 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 30 Aug 2026 · Direct link

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28 Aug 2024 a former US futures exchangeFormer futures exchange: 22 million USD over hidden volume incentives and false statements USADisclosure and reporting obligationsanonymised €19.8m

The CFTC fined the former designated contract market 22 million USD. Between 2015 and 2018, the exchange made volume-based payments to certain participants in its market maker programme on top of the disclosed fixed stipend, did not disclose this to the CFTC, the public, its own compliance staff or its regulatory service provider, and made false and misleading statements to the CFTC about it. It also failed to follow its regulatory service provider's recommendation concerning certain trading activity and did not record why.

What organisations can take from it

A trading venue's incentive programmes must be fully disclosed and known to its own compliance function; inaccurate information given to the supervisor is a separate breach.

Relevance to training and awareness

Truthful and complete statements to supervisory authorities

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Sections 5(d)(2), 5(d)(7), 5(d)(12) und 6(c)(2) Commodity Exchange Act; CFTC Regulations 38.150, 38.154(c), 38.400, 38.401(b), 38.650, 38.651, 38.4(b) und 40.6
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
29 Aug 2024

Original amount 22,000,000 USD, converted at the ECB reference rate of 28 Aug 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 28 Aug 2026 · Direct link

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27 Aug 2024 a European major bankNYDFS: USD 35 million against a European major bank for AML failures in foreign branches USA, New YorkCustomer due diligenceanonymised €31.4m

The NYDFS imposed a penalty of allegedly USD 35 million on a European major bank and its branch in New York. The bank had not maintained an effective AML programme in several foreign branches, had not adequately reviewed correspondent banking and RMA relationships and had not operated adequate transaction monitoring; it also helped customers set up hundreds of offshore accounts.

What organisations can take from it

AML weaknesses in individual foreign units reflect on the whole group and must be managed group-wide.

Relevance to training and awareness

Group-wide anti-money laundering and due diligence in correspondent banking

Authority / court
New York State Department of Financial Services (NYDFS)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
3 N.Y.C.R.R. § 116.2; 3 N.Y.C.R.R. § 504.3 (so zitiert); New York Banking Law §§ 39, 44
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
The NYDFS gave substantial weight to the bank's extensive cooperation during the investigation and its remediation efforts, including substantial investment in compliance resources.
Published
27 Aug 2024

Original amount 35,000,000 USD, converted at the ECB reference rate of 27 Aug 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 27 Aug 2026 · Direct link

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26 Aug 2024 an Australian bankAustralian bank: record AUD 4.995m penalty over suspicious electricity futures orders AustraliaMarket abuse and insider dealinganonymised €3.03m

Between January and September 2022, as a market participant on ASX 24, the bank allowed 50 orders by three clients in electricity futures which it ought to have suspected were intended to influence the settlement price shortly before the close (“marking the close”). The MDP issued an infringement notice, allegedly, of AUD 4.995 million, the highest MDP penalty to date; aggravating factors were that the bank did not respond in time to several warnings from ASIC and left a known gap in its trade surveillance open for months.

What organisations can take from it

Market participants must close surveillance gaps immediately with interim solutions and take regulators’ warnings about suspicious client trading seriously.

Relevance to training and awareness

Trade surveillance and handling of suspicious client orders (gatekeeper obligations)

Missing or inadequate training played a role in the decision.

Authority / court
Markets Disciplinary Panel (MDP) der Australian Securities and Investments Commission (ASIC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Rule 3.1.2(1)(b)(iii) ASIC Market Integrity Rules (Futures Markets) 2017; s 798H(1) Corporations Act 2001 (Cth)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The bank accepted the breaches and agreed to a joint statement of facts.
Published
25 Sep 2024

Original amount 4,995,000 AUD, converted at the ECB reference rate of 26 Aug 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 26 Aug 2026 · Direct link

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20 Aug 2024 a Polish bankPolish bank: 4.05 million PLN for failing to inform customers after misdirected mailing PolandData breaches and data securityanonymised €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
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.

Checked against the official source on 28 Sep 2026 · Version 5 · Company name anonymised since 20 Aug 2026 · Direct link

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14 Aug 2024 a money services business based in British ColumbiaFINTRAC: CAD 229,350 penalty on money services business based in British Columbia for 5 violations of anti-money laundering obligations CanadaInternal controlsanonymised €151,737

According to FINTRAC, the company is a money services business based in Surrey, British Columbia. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 229,350 on the company on 14 August 2024. According to FINTRAC's findings, made during a compliance examination in 2022, the company committed 5 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned reporting of incoming international electronic funds transfers of CAD 10,000 or more, written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the prescribed review of the compliance programme and compliance with a ministerial directive. Specifically, FINTRAC found 21 unreported incoming international transfers; contrary to the ministerial directive on Iran, the company also failed to report 21 transactions originating from Iran. According to FINTRAC, the company has appealed the decision to the Federal Court. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 9(1), 9.6(1), 11.43; PCMLTF Regulations 28(1)(a), 71(1)(b), 71(1)(c), 71(1)(e); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
28 Nov 2024

Original amount 229,350 CAD, converted at the ECB reference rate of 14 Aug 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 14 Aug 2026 · Direct link

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12 Aug 2024 a German digital bankBaFin: EUR 1.25 million fine on a digital bank over late suspicious activity reports GermanySuspicious activity reportsanonymised €1.25m

BaFin imposed a fine of EUR 1,250,000 on a German digital bank. According to BaFin, between March 2021 and June 2023 the institution systematically filed money laundering suspicious activity reports with the FIU late. According to BaFin, the decision is final.

What organisations can take from it

Suspicious activity reports brook no delay; filing them systematically late over years can lead to a fine in the millions.

Relevance to training and awareness

Filing suspicious activity reports with the FIU on time

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
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
1 Oct 2024

Checked against the official source on 2 Oct 2026 · Company name anonymised since 12 Aug 2026 · Direct link

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9 Aug 2024 a Cypriot CFD providerFCA: £276,100 fine for Cypriot CFD provider over unfair treatment of CFD customers United KingdomConsumer protection and online retailanonymised €322,140

The FCA fined a Cypriot CFD provider £276,100. The FCA found that between January and April 2021 the firm's account managers pushed often inexperienced UK retail customers into trading risky leveraged contracts for difference and gave investment advice without permission to do so. According to the FCA, UK customers lost around £4.4 million in that period. The fine was significantly reduced because of proven serious financial hardship; £1,736,000 had originally been proposed.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Consumer protection and online retail
Legal basis
FCA Principle 6; section 20(1) FSMA 2000; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 276,100 GBP, converted at the ECB reference rate of 9 Aug 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 9 Aug 2026 · Direct link

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2 Aug 2024 an Australian superannuation trusteeSuperannuation trustee: AUD 11.3m penalty for misleading sustainability claims AustraliaMisleading environmental and sustainability claimsanonymised €6.8m

On its website the superannuation trustee promoted seven investment options of its superannuation fund marketed as sustainable as excluding companies involved in carbon-intensive fossil fuels, alcohol production and gambling; in fact six of the seven options held interests in such companies. Following admissions, the Court imposed AUD 11.3 million and ordered a court-prescribed notice on the website for six months. It was ASIC’s first greenwashing case before the Federal Court.

What organisations can take from it

Marketing claims about exclusion criteria need a control process that continuously checks actual portfolio holdings against the promises made.

Relevance to training and awareness

Review and sign-off of sustainability claims in marketing and on websites

Authority / court
Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
ss 12DB(1)(a), 12DF(1) ASIC Act 2001 (Cth)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Early admission, full cooperation with ASIC, removal of the statements and clearer disclosure in an information booklet from April 2023.
Liability of senior managers
According to the Court’s findings, persons at senior management level were involved; there were no mandatory sign-off processes for website content.
Published
2 Aug 2024

Original amount 11,300,000 AUD, converted at the ECB reference rate of 2 Aug 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 2 Aug 2026 · Direct link

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2 Aug 2024 a UK asset managerFCA: Public censure for asset manager over risky illiquid fund investments United KingdomOrganisational requirementsanonymised Reprimand or warning

The FCA publicly censured a UK asset manager. The FCA found that, as manager of several French UCITS funds, between April 2015 and November 2019 the company invested in mostly unlisted, hard-to-sell assets without adequate due diligence, risk management and conflicts management; its trading records were also deficient and it did not deal with the FCA in an open and cooperative way. Under the settlement the group secured EUR 250 million for affected unitholders, waived fees and investments of EUR 320 million and agreed to give up its UK permissions.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
FCA Principles 2, 3 und 11; section 205 FSMA 2000
Action
Reprimand or warning
Status of proceedings
final
Sector
Financial services and insurance

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 2 Aug 2026 · Direct link

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26 Jul 2024 an Emirati insurance brokerCBUAE revokes insurance broker's licence over weak compliance United Arab EmiratesOrganisational requirementsanonymised Other

Following an examination, the Central Bank found that the insurance broker had a weak compliance framework and did not meet its regulatory obligations. It revoked the broker's licence and struck it off the register.

What organisations can take from it

For insurance intermediaries, a persistently weak compliance framework can lead directly to the loss of their licence.

Relevance to training and awareness

Minimum compliance requirements for insurance intermediaries

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 22(2) Board of Directors Resolution No. 15 of 2013 Concerning Insurance Brokerage Regulations
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
26 Jul 2024

Checked against the official source on 7 Oct 2026 · Company name anonymised since 26 Jul 2026 · Direct link

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23 Jul 2024 a UK e-money institutionFCA: £3.5m fine for crypto exchange subsidiary over onboarding high-risk customers United KingdomInternal controlsanonymised €4.17m

The FCA fined a UK e-money institution belonging to a US crypto exchange group, £3,503,546. The FCA found that the firm had voluntarily agreed with the FCA not to onboard high-risk customers, but between October 2020 and October 2023 it repeatedly breached this and served 13,416 such customers. In the FCA's view, the cause was poorly designed, tested and monitored controls. The fine includes a 30% settlement discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Regulation 51(1)(a) Electronic Money Regulations 2011; FCA Principle 2
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 3,503,546 GBP, converted at the ECB reference rate of 23 Jul 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 23 Jul 2026 · Direct link

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5 Jul 2024 a Hong Kong commercial bankCommercial bank (Hong Kong): HKD 10m penalty for breaches of due diligence duties Hong KongCustomer due diligenceanonymised €1.18m

The commercial bank must pay a pecuniary penalty of 10,000,000 HKD because it breached due diligence duties under the AMLO in various periods between April 2012 and April 2019. Among other things, up to July 2017 it did not verify the identity of 609 persons whom 477 corporate customers had registered as authorisers in its corporate internet banking, did not complete trigger-event reviews for 23 customers, failed to identify suspicious transactions when reviewing transaction-monitoring alerts for 15 customers and did not establish the source of wealth and funds of high-risk customers; record-keeping and procedural failings came on top.

What organisations can take from it

Persons who approve payments on behalf of corporate customers also belong in identity verification.

Relevance to training and awareness

Customer due diligence in corporate banking and handling of monitoring alerts

Authority / court
Hong Kong Monetary Authority (HKMA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
s. 21(2)(c) AMLO (Cap. 615); Schedule 2 ss. 5(1)(a), 5(1)(c), 15(a), 19(3), 20(3) AMLO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Remedial measures and improved AML controls, no previous disciplinary record under the AMLO, cooperation.
Published
5 Jul 2024

Original amount 10,000,000 HKD, converted at the ECB reference rate of 5 Jul 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 5 Jul 2026 · Direct link

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5 Jul 2024 a South African insurerPA: ZAR 13m against an insurer over flaws in its anti-money laundering programme South AfricaCustomer due diligenceanonymised €658,658

Following a FIC Act inspection in 2020, the insurer was sanctioned for inadequate customer due diligence (including on domestic prominent influential persons), missing records for client files and an inadequately developed risk management and compliance programme. It received three cautions and financial penalties of ZAR 13m (10m for customer due diligence, 3m for the RMCP), of which ZAR 6m is conditionally suspended for 36 months.

What organisations can take from it

Insurers, too, must assess money laundering risks using a documented method and keep client files complete.

Relevance to training and awareness

Risk-based customer checks and record-keeping at insurers

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 21(1), 21A–21H, 22, 23, 42
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation and remediation of the deficiencies; ZAR 6m conditionally suspended.
Published
5 Jul 2024

Original amount 13,000,000 ZAR, converted at the ECB reference rate of 5 Jul 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 5 Jul 2026 · Direct link

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3 Jul 2024 a Swiss major bank and its Singapore subsidiaryNaked short selling: KRW 27.2bn against two former entities of a Swiss major bank South KoreaMarket abuse and insider dealinganonymised €18.2m

The Securities and Futures Commission (SFC) of the Financial Services Commission (Korea's financial regulator) found that the Swiss bank (now part of another banking group) had placed short sale orders worth around KRW 60.33 billion (162,365 shares in 20 stocks) between 7 April 2021 and 9 June 2022, and its Singapore subsidiary orders worth around KRW 35.28 billion (401,195 shares in five stocks) between 29 November 2021 and 9 June 2022, without holding the shares. At its meeting on 3 July 2024 it imposed fines totalling KRW 27,173 million (around KRW 16.94 billion on the Swiss bank and around KRW 10.23 billion on the Singapore subsidiary), according to the FSC the highest and third-highest individual fines for naked short selling since such fines were introduced in April 2021.

What organisations can take from it

Trading systems must check before every sell order whether the securities are actually held or borrowed.

Relevance to training and awareness

Short selling rules and position checks before placing orders

Authority / court
Securities and Futures Commission (SFC) der Financial Services Commission (FSC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Leerverkaufsvorschriften des Financial Investment Services and Capital Markets Act (FSCMA)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Published
3 Jul 2024

Original amount 27,173,000,000 KRW, converted at the ECB reference rate of 3 Jul 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 3 Jul 2026 · Direct link

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3 Jul 2024 a French major bankBaFin fines a French major bank €830,000 over cost disclosures and suitability assessments GermanyOrganisational requirementsanonymised €830,000

On 3 July 2024 BaFin (German Federal Financial Supervisory Authority) imposed fines totalling 830,000 EUR on a French major bank. In individual cases in the 2019/2020 financial year, its German branch had not informed clients on time and as required about all costs and associated charges of financial instruments, and had provided investment services without obtaining sufficient information on clients' financial situation in the suitability assessment. The fine is final.

What organisations can take from it

Cost disclosure and suitability assessment are core investor protection duties; even individual failures lead to high fines.

Relevance to training and awareness

Carrying out MiFID II cost disclosures and suitability assessments correctly

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
§ 63 Abs. 7 bis 9 WpHG, Art. 46 Abs. 2 und Art. 50 Abs. 2 Delegierte Verordnung (EU) 2017/565; § 64 Abs. 3 WpHG i. V. m. Art. 54 Abs. 4 Delegierte Verordnung (EU) 2017/565
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
25 Jul 2024

Checked against the official source on 2 Oct 2026 · Company name anonymised since 3 Jul 2026 · Direct link

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26 Jun 2024 a Slovak bankNBS: EUR 500,000 fine for a Slovak bank over misleading savings account advertising SlovakiaMisleading advertising and pricinganonymised €500,000

The Národná banka Slovenska (NBS, National Bank of Slovakia) imposed an aggregate fine of 500,000 EUR on the bank. Posters at numerous branches and 1,051 TV spots on one television channel and 2,908 on another advertised a savings account from January to March 2023 without adequately stating material conditions such as the savings period and the minimum and maximum deposit (misleading omission); this was a repeated breach within twelve months of an NBS decision of 9 January 2023. The NBS Bank Board amended the wording on 9 September 2025 but upheld the amount.

What organisations can take from it

Advertising for savings and account products must show the material conditions prominently; after a first finding, the supervisor treats repeat breaches particularly strictly.

Relevance to training and awareness

Mandatory information in advertising for financial products

Authority / court
Národná banka Slovenska (NBS)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
§ 35f Abs. 1 lit. a und Abs. 2, § 35h Abs. 1 und 3 Zákon č. 747/2004 Z. z. (Finanzmarktaufsichtsgesetz); § 4 Abs. 2 lit. c, § 7 Abs. 1 und 4, § 8 Abs. 3 und 4 Zákon č. 250/2007 Z. z. (Verbraucherschutzgesetz)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes

Checked against the official source on 28 Sep 2026 · Company name anonymised since 26 Jun 2026 · Direct link

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24 Jun 2024 a major Japanese bank and two group securities firmsMajor Japanese bank and two securities firms: orders over firewall breaches JapanOrganisational requirementsanonymised Order

The two group securities firms and the bank received business improvement orders; the bank and the group holding company also had to report under the Banking Act. The firms had repeatedly, at one of the securities firms at least 13 times, exchanged non-public client information although the clients had prohibited this or had not consented, and in some cases used such information to win underwriting mandates. The bank also improperly negotiated underwriting allocations for that securities firm and in at least one case made this a condition of a loan agreement.

What organisations can take from it

Information barriers within a financial group need controls that also cover board level and any tying of lending to underwriting business.

Relevance to training and awareness

Handling non-public client information within a financial group

Authority / court
Financial Services Agency (FSA, 金融庁) auf Empfehlung der Securities and Exchange Surveillance Commission (SESC, 証券取引等監視委員会)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Financial Instruments and Exchange Act (FIEA, 金融商品取引法) Art. 51 und Art. 51-2; Art. 44-3 Abs. 1 Nr. 4 FIEA i. V. m. Art. 153 Abs. 1 Nr. 7 und 8 sowie Art. 40 Nr. 2 FIEA i. V. m. Art. 123 Abs. 1 Nr. 5 Cabinet Office Order on Financial Instruments Business; Art. 33 Abs. 1 und Art. 44-3 Abs. 1 Nr. 2 FIEA; Banking Act (銀行法) Art. 24 Abs. 1, Art. 52-31 Abs. 1
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
A then Deputy President of that securities firm personally received confidential client information from an executive officer of the bank; the orders required responsibility, including that of management, to be clarified.
Published
24 Jun 2024

Checked against the official source on 8 Oct 2026 · Company name anonymised since 24 Jun 2026 · Direct link

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19 Jun 2024 an Italian insurer in compulsory liquidationIVASS fines insurer €8.28m for serious risk management failings ItalyOrganisational requirementsanonymised €8.28m

The insurance supervisor IVASS imposed a fine of 8,280,000 EUR on the insurer, which has been in compulsory administrative liquidation since 27 October 2023, under Art. 310(1) of the Private Insurance Code (CAP). It found serious shortcomings in the governance, management and control of financial risks, including, up to the 2020 financial year, in the calculation of best estimate liabilities, weaknesses in the solvency assessment and the risk appetite framework, and late implementation of a remediation plan drawn up after an earlier IVASS inspection. On the same day IVASS imposed a further 312,682.50 EUR in a separate decision for breaches of anti-money laundering law.

What organisations can take from it

A remediation plan drawn up after a supervisory inspection must be implemented promptly; delaying it is itself a ground for sanctions.

Relevance to training and awareness

Risk management and solvency assessment at insurers

Authority / court
IVASS (Istituto per la Vigilanza sulle Assicurazioni)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 30, 30-bis, 30-ter, 35-quater, 36-bis, 37-ter, 47-quater und 310 Abs. 1 D.Lgs. 209/2005 (Codice delle assicurazioni private, CAP); IVASS-Verordnungen 18/2016, 24/2016, 32/2016, 34/2017 und 38/2018
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not reported here.
Published
31 Jul 2024

Checked against the official source on 28 Sep 2026 · Company name anonymised since 19 Jun 2026 · Direct link

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19 Jun 2024 an Italian mutual insurerIVASS fines insurer €207,500 over customer due diligence failings ItalyCustomer due diligenceanonymised €207,500

IVASS (Italian insurance supervisor) imposed a fine of 207,500 EUR on the mutual insurer under Art. 62(1) of Legislative Decree 231/2007. The insurer had not adequately identified the beneficial owners in ongoing contractual relationships and, where contracts were assigned, had gathered too little information on their purpose, on whether the premiums matched the customer's financial situation and on the source of funds.

What organisations can take from it

Insurers, too, must verify beneficial owners and the source of funds, especially when contracts are transferred to third parties.

Relevance to training and awareness

Beneficial ownership and source of funds in insurance contracts

Authority / court
IVASS (Istituto per la Vigilanza sulle Assicurazioni)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 16 Abs. 1, Art. 18 Abs. 1 lit. b und c sowie Art. 62 Abs. 1 D.Lgs. 231/2007; Art. 11, 14, 35 und 37 IVASS-Verordnung 44/2019
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
31 Jul 2024

Checked against the official source on 28 Sep 2026 · Company name anonymised since 19 Jun 2026 · Direct link

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18 Jun 2024 a Swedish stock exchangeSwedish stock exchange: SEK 100m for deficient surveillance of insider dealing SwedenMarket abuse and insider dealinganonymised €8.88m

Finansinspektionen (FI, Swedish Financial Supervisory Authority) issued the exchange a remark and an administrative fine of 100,000,000 SEK. In four major corporate events in 2021 and 2022, trade surveillance did not analyse suspicious trading in more detail, so suspected insider dealing was neither detected nor reported to FI; in addition, in two cases in 2022 and 2023 the exchange admitted financial instruments to trading before a prospectus had been approved, registered and published. According to the decision, the exchange had 180 employees and a turnover of 2,103 million SEK in 2023.

What organisations can take from it

Trading venue operators must actively analyse unusual trading patterns ahead of corporate announcements and report suspicions; an alert without follow-up is not enough.

Relevance to training and awareness

Trade surveillance and suspicious transaction reporting on insider dealing

Authority / court
Finansinspektionen (FI)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 16 Abs. 1 Verordnung (EU) Nr. 596/2014 (MAR); 13 kap. 3 och 7 §§ lagen (2007:528) om värdepappersmarknaden; 25 kap. 1 och 8 §§ LV
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
50 to 249
Mitigating circumstances
Individual cases within a limited period, no established damage, committed improvements; no trading took place in the wrongly admitted instruments. FI did not regard the cooperation as mitigating.
Published
19 Jun 2024

Original amount 100,000,000 SEK, converted at the ECB reference rate of 18 Jun 2024.

Checked against the official source on 28 Sep 2026 · Company name anonymised since 18 Jun 2026 · Direct link

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18 Jun 2024 a Swedish cash-in-transit companyCash-in-transit company: SEK 40m for money laundering failings in cash deposit services SwedenCustomer due diligenceanonymised €3.55m

Finansinspektionen (FI, Swedish Financial Supervisory Authority) issued the cash-in-transit and payment institution a remark and an administrative fine of 40,000,000 SEK for breaches in its cash counting business (uppräkningsverksamhet). The general risk assessment did not adequately address geographical risks and cash-intensive customers, customers were not risk-assessed individually, and there were shortcomings in both basic and enhanced due diligence – in some cases no information at all was obtained on the purpose and nature of the business relationship; cash deposits of 11.7 billion SEK from foreign banks were processed without sufficient checks on the source of funds.

What organisations can take from it

Cash-intensive services require a risk assessment for each customer and robust source-of-funds checks, especially for deposits from abroad.

Relevance to training and awareness

Customer due diligence and source-of-funds checks for cash-intensive customers

Authority / court
Finansinspektionen (FI)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Lag (2017:630) om åtgärder mot penningtvätt och finansiering av terrorism, u. a. 2 kap. 1–3 §§, 3 kap. 12 och 16 §§; 8 kap. 8 och 14 §§ lagen (2010:751) om betaltjänster
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Published
19 Jun 2024

Original amount 40,000,000 SEK, converted at the ECB reference rate of 18 Jun 2024.

Checked against the official source on 28 Sep 2026 · Company name anonymised since 18 Jun 2026 · Direct link

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18 Jun 2024 a Swiss private bankFINMA: Swiss private bank breached anti-money laundering rules for two PEPs SwitzerlandCustomer due diligenceanonymised Order

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

What organisations can take from it

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

Relevance to training and awareness

Dealing with politically exposed persons (PEPs)

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

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 18 Jun 2026 · Direct link

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14 Jun 2024 a UK financial services firmFCA halts UK financial services firm after missing transaction reports United KingdomDisclosure and reporting obligationsanonymised Order

The FCA required the firm to cease all regulated activities immediately, to inform its clients and to preserve all records. Since April 2023 the firm had repeatedly failed to report all executed transactions under Art. 26(1) UK MiFIR, had in the FCA's assessment given it incomplete or inaccurate information, had not submitted audited accounts and had not notified a pending strike-off from the register of companies.

What organisations can take from it

Transaction reporting is no formality: a firm that persistently fails to report and keeps the regulator poorly informed effectively loses its permission to do business.

Relevance to training and awareness

Transaction reporting under UK MiFIR

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
s. 55L(3)(a) und (b) FSMA 2000; Art. 26(1) UK MiFIR; Principle 11 der FCA Principles for Businesses; SUP 16.7A.3R; SUP 15.3.21R
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Sources

Checked against the official source on 3 Oct 2026 · Company name anonymised since 14 Jun 2026 · Direct link

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7 Jun 2024 a US custody bankOFAC: USD 7.45m settlement with US custody bank over invoices from a software subsidiary to Russian customers USABreaches of sanctions and embargoesanonymised €6.84m

A Massachusetts custody bank is paying USD 7,452,501 under a settlement with OFAC on behalf of itself and its software subsidiary for 38 apparent violations of the Ukraine-/Russia-related sanctions. According to OFAC's findings, between 2016 and 2020 the software subsidiary repeatedly redated or reissued invoices worth around USD 1.27 million to customers subject to Directive 1 under Executive Order 13662 and accepted payments after the permitted debt tenors had expired, which amounted to prohibited new debt. OFAC treated the apparent violations as egregious and not voluntarily self-disclosed and took cooperation and remediation into account; the base penalty equalled the statutory maximum of USD 13,550,002. OFAC signed the settlement agreement on 7 June 2024 and published it on 26 July 2024. Summarised in our own words.

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. § 589.202 i. V. m. Directive 1 zu E.O. 13662 (38 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
26 Jul 2024

Original amount 7,452,501 USD, converted at the ECB reference rate of 7 Jun 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 7 Jun 2026 · Direct link

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7 Jun 2024 a South African branch of a foreign bankPA: ZAR 30.5m against a foreign bank's branch over customer due diligence failures South AfricaCustomer due diligenceanonymised €1.49m

Following a FIC Act inspection in 2021 (samples from 2016–2020), the supervisor sanctioned the South African branch for failing to carry out (enhanced) customer due diligence, late suspicious transaction reports, monitoring alerts not handled on time and an inadequate risk management and compliance programme. It imposed four cautions, a reprimand and financial penalties totalling ZAR 30.5m (20m for due diligence, 0.5m for alert handling, 10m for the RMCP), of which ZAR 15.25m is conditionally suspended for 36 months. According to the supervisor, the sanctions do not stem from any involvement of the branch in money laundering or terrorist financing transactions.

What organisations can take from it

Foreign branches also need their own anti-money laundering programme, approved by the governing body, that actually drives customer due diligence and alert handling.

Relevance to training and awareness

Customer due diligence and timely handling of monitoring alerts

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 21(1), 21A, 29 i. V. m. Regulation 24(3), s. 42; FIC Directive 5 of 2019
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation with the supervisor and remedial action; half of the penalty was conditionally suspended.
Liability of senior managers
The programme had not been approved by the Board of Directors and was not tailored to the branch.
Published
7 Jun 2024

Original amount 30,500,000 ZAR, converted at the ECB reference rate of 7 Jun 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 7 Jun 2026 · Direct link

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31 May 2024 a money services business based in British ColumbiaFINTRAC: CAD 33,000 penalty on money services business for one violation of anti-money laundering obligations CanadaInternal controlsanonymised €22,291

According to FINTRAC, the company is a money services business based in Richmond, British Columbia. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 33,000 on the company on 31 May 2024. According to FINTRAC's findings, the company committed one violation of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violation concerned money services business registration requirements. According to FINTRAC, the penalty has been paid in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 11.19; PCMLTF Registration Regulations s. 4(e), 5, 6.1; Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
19 Sep 2024

Original amount 33,000 CAD, converted at the ECB reference rate of 31 May 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 31 May 2026 · Direct link

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24 May 2024 a German investment firm of an international banking groupBaFin fines an investment firm €12.975m over algorithmic trading controls GermanyOrganisational requirementsanonymised €13m

On 24 May 2024 BaFin (German Federal Financial Supervisory Authority) imposed a fine of 12,975,000 EUR on a German investment firm of an international banking group. In May 2022 the investment firm lacked suitable systems and risk controls with appropriate trading thresholds and limits for its algorithmic trading; a manual input error by a trader at a sister company in London, to which monitoring had been outsourced, went undetected and caused a market disruption. The fine is final.

What organisations can take from it

A firm that outsources the monitoring of its algorithmic trading remains fully responsible for effective trading limits and controls against erroneous orders.

Relevance to training and awareness

Outsourcing does not remove responsibility for trading controls

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
§ 80 Abs. 2 S. 3 Nr. 1 und 2 WpHG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
20 Jun 2024

Checked against the official source on 2 Oct 2026 · Company name anonymised since 24 May 2026 · Direct link

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24 May 2024 a UK broker of emergency property loans and a property purchasing companyHigh Court: restitution orders against two firms over unauthorised financial business United KingdomCapital markets and financial supervisionanonymised Order

In proceedings brought by the FCA, the High Court found that a loan broker arranged mortgage loans for homeowners in financial difficulty without authorisation and that a property purchasing company bought their properties and rented them back to them without authorisation. The court ruled on relief for 45 affected individuals from the first judgment of 2022 and 26 further individuals: it made restitution orders for the losses suffered, against the purchasing company in the sale-and-rent-back cases, and required the broker to remove land registry restrictions it had used to extract excessive fees. The companies' share of the payments ordered is not stated here as a separate amount. Measures against individuals are not set out here.

What organisations can take from it

Arranging loans, or buying and renting back homes from owners in distress, requires authorisation – otherwise unwinding and compensation for all losses follow.

Authority / court
High Court of Justice, Business and Property Courts (Klage: Financial Conduct Authority (FCA))
Area of law
Capital markets and financial supervision
Legal basis
ss. 19, 21, 380 und 382 FSMA 2000
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
5 Aug 2024
Sources

Checked against the official source on 3 Oct 2026 · Company name anonymised since 24 May 2026 · Direct link

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23 May 2024 a US futures commission merchant and swap dealerFutures commission merchant: 200 million USD over gaps in trade surveillance USAOrganisational requirementsanonymised €184.3m

The CFTC fined the futures commission merchant and swap dealer 200 million USD for failing to supervise its business diligently. Because data feeds were misconfigured and data delivered directly by exchanges was not reconciled for completeness, billions of order messages on a US designated contract market went unsurveilled from 2014 to 2021. 50 million USD each from the March 2024 resolutions with the Office of the Comptroller of the Currency and the Federal Reserve Board is credited against the fine.

What organisations can take from it

Even data received directly from exchanges must be checked regularly for completeness before trade surveillance relies on it.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
CFTC Regulation 166.3 (17 C.F.R. § 166.3)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The firm admitted the findings on the scope and causes of the surveillance gaps, has by its own account put a remediation programme in place and closed the gaps by 2023.
Published
23 May 2024

Original amount 200,000,000 USD, converted at the ECB reference rate of 23 May 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 23 May 2026 · Direct link

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23 May 2024 a major UK bankFCA: £6.3m fine for major UK bank over treatment of customers in financial difficulty United KingdomConsumer protection and online retailanonymised €7.37m

The FCA fined a major UK bank £6,280,100. The FCA found that between June 2017 and October 2018 the bank did not treat customers in arrears or financial difficulty fairly: payment arrangements were agreed without proper affordability checks and forbearance was not always applied. At least 1.5 million customers across mortgages, loans, credit cards and overdrafts were affected; the bank has paid around £185 million in redress. The fine includes a 30% discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Consumer protection and online retail
Legal basis
FCA Principles 3 und 6; CONC 7.2.1R, 7.3.4R, 7.3.14R; MCOB 13.3.2A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 6,280,100 GBP, converted at the ECB reference rate of 23 May 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 23 May 2026 · Direct link

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22 May 2024 a US exchange group and nine of its subsidiariesUS exchange group: 10 million USD – cyber attack not reported to the SEC USAIncident reporting obligationsanonymised €9.23m

In April 2021, a third party alerted the group to a vulnerability in its VPN; the group 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 a stock exchange, did not immediately report the incident to the U.S. Securities and Exchange Commission (SEC) as required under Regulation SCI; the group 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 28 Sep 2026 · Version 4 · Company name anonymised since 22 May 2026 · Direct link

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21 May 2024 three companies of a Brazilian crypto investment providerCVM imposes BRL 44.71m on crypto investment provider over fraudulent bitcoin investment BrazilMarket abuse and insider dealinganonymised €8.07m

The board of the Comissão de Valores Mobiliários (CVM, Brazilian Securities and Exchange Commission) fined the Brazilian operating company of a crypto investment offering and an international sister company BRL 22,100,000 each for fraudulent transactions in the securities market (operação fraudulenta) and BRL 170,000 each for obstructing supervision; a third company was fined BRL 170,000 for obstructing supervision and acquitted of the fraud charge. The allegations were that investors in a publicly promoted bitcoin arbitrage offering had been deceived by, among other things, false return figures, misleading announcements and wrongly blocked withdrawals, and that CVM requests for information had gone unanswered.

What organisations can take from it

Anyone publicly marketing crypto investments with promised returns is subject to securities supervision and must answer the regulator's requests for information.

Relevance to training and awareness

Advertising with return figures and cooperation with the supervisor

Authority / court
Comissão de Valores Mobiliários (CVM)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Instrução CVM nº 8/1979, Ziff. I i. V. m. II c; Instrução CVM nº 607/2019, Anexo 64, Art. 1 IV
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
21 May 2024

Original amount 44,710,000 BRL, converted at the ECB reference rate of 21 May 2024.

Checked against the official source on 14 Oct 2026 · Company name anonymised since 21 May 2026 · Direct link

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17 May 2024 a London-based investment bankFCA: £27.8m fine for investment bank over trading control failures United KingdomOrganisational requirementsanonymised €32.4m

The FCA fined a London-based investment bank £27,766,200. The FCA found that a trader entered an erroneous basket order and overrode the warnings; because of inadequate trading controls, erroneous orders with a notional value of USD 196 billion were generated in the electronic trading system, of which USD 1.4 billion of sell orders were executed on European venues. The FCA criticised ineffective pre-trade and post-trade controls. The fine includes a 30% discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
FCA Principles 2 und 3; MAR 7A.3.2R; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 27,766,200 GBP, converted at the ECB reference rate of 17 May 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 17 May 2026 · Direct link

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16 May 2024 a digital investment management firm in the DIFCDFSA: digital investment manager offered own shares without a prospectus – USD 191,100 United Arab EmiratesDisclosure and reporting obligationsanonymised €175,870

The DIFC entity of a digital investment management group emailed almost 100,000 users an offer of shares in its parent company without an approved prospectus, withholding financial information while highlighting positive metrics. The DFSA imposed USD 191,100; the firm had halted the sale immediately after the regulator's warning and returned all monies. In parallel, the FSRA of ADGM separately sanctioned the sister company.

What organisations can take from it

Even a 'test offer' of a firm's own shares to its customer base is a public offer and requires an approved prospectus.

Relevance to training and awareness

Prospectus requirement for share offers to customers

Authority / court
Dubai Financial Services Authority (DFSA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 90(2)(a) Regulatory Law 2004 (DIFC); Art. 11 und Art. 14 Markets Law 2012 (DIFC); Art. 41B Regulatory Law
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Immediate halt of the offer and return of all monies; settlement (30% discount); account taken of the parallel ADGM sanction.
Published
21 May 2024

Original amount 191,100 USD, converted at the ECB reference rate of 16 May 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 16 May 2026 · Direct link

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15 May 2024 a UAE investment app providerADGM: 122,500 USD fine for an investment app over share offer without a prospectus United Arab EmiratesDisclosure and reporting obligationsanonymised €113,091

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the operator of an investment and trading app 122,500 USD and required it to have its governance, systems and controls reviewed by an independent third party. In April and May 2023 the firm used emails (the first sent to 96,701 recipients) and its website to promote the purchase, through a special purpose vehicle, of shares in its own group from existing shareholders without an approved prospectus. The regulator considered the conduct reckless rather than deliberate; because of mitigating factors, including the prompt reversal of the transactions without investor detriment, it reduced the fine by 30% and granted a further 30% discount for settlement.

What organisations can take from it

A firm marketing shares in its own group to its customers must obtain legal advice on prospectus requirements beforehand.

Relevance to training and awareness

Prospectus requirements when marketing shares to customers

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Sections 58(1), 61(1), 232 und 35 FSMR 2015
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
negligent
Mitigating circumstances
Full cooperation, prompt reversal without investor detriment, prior notice of the plan to the regulator (though without legal advice), short duration, no previous similar non-compliance; a settlement on similar terms was also reached with another UAE authority.

Original amount 122,500 USD, converted at the ECB reference rate of 15 May 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 15 May 2026 · Direct link

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7 May 2024 a foreign crypto exchangeFINTRAC: CAD 6,002,000 penalty on foreign crypto exchange for 2 violations of anti-money laundering obligations CanadaInternal controlsanonymised €4.07m

According to FINTRAC, the company is an entity determined to be a foreign money services business operating in Canada. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 6,002,000 on the company on 7 May 2024. According to FINTRAC's findings, the company committed 2 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned money services business registration requirements and large virtual currency transaction reporting. According to FINTRAC, the company had not completed registration despite several opportunities and deadlines; the regulator identified unreported virtual currency receipts of CAD 10,000 or more using blockchain analytics. According to FINTRAC, the company has appealed the decision to the Federal Court. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTFA s. 11.1; PCMLTF Regulations 30(1)(f); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
9 May 2024

Original amount 6,002,000 CAD, converted at the ECB reference rate of 7 May 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 7 May 2026 · Direct link

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7 May 2024 an Italian supplementary health insurer and its claims-handling service providerAGCM fines health insurer and claims-handling provider €3.5m ItalyConsumer protection and online retailanonymised €3.5m

From January 2023, the supplementary health insurer and the service provider it had entrusted with claims handling delayed reimbursements and authorisations, in some cases refused them without justification and provided inadequate customer service; the AGCM treated this as aggressive obstruction of the insured persons' contractual rights. Fines of 2,500,000 EUR on the insurer and 1,000,000 EUR on the service provider were imposed, a total of 3,500,000 EUR.

What organisations can take from it

Outsourcing claims handling does not release an insurer from responsibility for processing times and customer service.

Relevance to training and awareness

Responsibility for outsourced claims handling and customer service

Authority / court
Autorità Garante della Concorrenza e del Mercato (AGCM)
Area of law
Consumer protection and online retail
Legal basis
Art. 20 Abs. 2, 24, 25 Abs. 1 lit. d Codice del consumo (D.lgs. 206/2005)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
For both companies, the AGCM took into account that their new service contract provides for stricter service levels and control tools and thereby contributed to improvements during the proceedings.
Published
21 May 2024

Checked against the official source on 28 Sep 2026 · Company name anonymised since 7 May 2026 · Direct link

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7 May 2024 a Singapore wealth and fund managerWealth manager: 2.5 million SGD for AML failings, CEO and COO reprimanded SingaporeInternal controlsanonymised €1.72m

At the wealth and fund manager, anti-money laundering controls did not keep pace with strong business growth between September 2015 and October 2018: the enterprise-wide risk assessment had gaps, business relations began before customer due diligence was completed, higher-risk customers were not identified or were insufficiently checked, suspicious transaction reports were not filed, and there was no internal audit. On 7 May 2024 the Monetary Authority of Singapore (MAS, Singapore's central bank and financial regulator) imposed a composition penalty of 2.5 million SGD and reprimanded the CEO and COO.

What organisations can take from it

When the business grows, risk assessment, customer due diligence and internal audit must grow with it; senior management is personally accountable for this.

Relevance to training and awareness

Anti-money laundering in wealth management during rapid growth

Authority / court
Monetary Authority of Singapore (MAS)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
MAS Notice SFA04-N02; s 27B(2) Monetary Authority of Singapore Act; Composition nach s 176(1A) MAS Act 1970; Rüge nach s 334(1) Securities and Futures Act 2001
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The company has remedied the deficiencies identified.
Liability of senior managers
Measures against individuals are not set out here.
Published
7 May 2024

Original amount 2,500,000 SGD, converted at the ECB reference rate of 7 May 2024.

Checked against the official source on 14 Oct 2026 · Company name anonymised since 7 May 2026 · Direct link

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2 May 2024 an Icelandic commercial bankIceland: commercial bank pays 585 million ISK over anti-money laundering failings IcelandCustomer due diligenceanonymised €3.9m

The financial supervisory authority of Seðlabanki Íslands (Central Bank of Iceland) concluded proceedings against an Icelandic commercial bank with a settlement in which the bank admitted breaches of Act No. 140/2018 on anti-money laundering, pays 585,000,000 ISK and commits to remedial measures. An on-site inspection in 2022 had found deficiencies in risk assessment, risk classification of business relationships, anonymous transactions, due diligence on foreign financial institutions, enhanced due diligence, business with a high-risk country and ongoing monitoring, including the traceability of cash transactions; some breaches repeated findings from a 2020 inspection.

What organisations can take from it

Findings from a supervisory inspection must be remedied for good, because repeated deficiencies count towards a higher sanction.

Relevance to training and awareness

Money laundering prevention: risk assessment, enhanced due diligence and cash transactions

Authority / court
Seðlabanki Íslands – Fjármálaeftirlit (Finanzaufsicht)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 5 Abs. 1, 7 Abs. 1, 10 Abs. 1, 2, 4 Bst. a und 5, 13 Abs. 1 Bst. c, 3 und 4, 15, 21 Abs. 1 Bst. a und 2 sowie 34 Abs. 1 Gesetz Nr. 140/2018 über Maßnahmen gegen Geldwäsche und Terrorismusfinanzierung (damalige Fassung) i.V.m. Verordnung Nr. 745/2019; Geldbuße nach Art. 46 Abs. 1, Vergleich nach Art. 47 Gesetz Nr. 140/2018
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
Willingness to cooperate: the bank took the inspection findings seriously and took the initiative on remediation.
Published
28 Jun 2024

Original amount 585,000,000 ISK, converted at the ECB reference rate of 2 May 2024.

Checked against the official source on 28 Sep 2026 · Company name anonymised since 2 May 2026 · Direct link

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24 Apr 2024 a German neobankBaFin: 9.2 million EUR against neobank over systematically late suspicious activity reports GermanySuspicious activity reportsanonymised €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 28 Sep 2026 · Version 4 · Company name anonymised since 24 Apr 2026 · Direct link

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19 Apr 2024 a Taiwanese commercial bank (Hong Kong branch)HKMA: HKD 9m fine for Taiwanese commercial bank over unreviewed alerts Hong KongInternal controlsanonymised €1.08m

The HKMA imposed a pecuniary penalty of HKD 9 million on the Hong Kong branch of a Taiwanese commercial bank. Between April 2012 and July 2018 most alerts generated by the transaction monitoring system introduced in 2011 went unreviewed; after discovering this in 2018, the bank reviewed more than 2,200 customers and retrospectively filed 304 suspicious transaction reports on 504 customers. In addition, recipient names were missing from a number of cross-border wire transfers between March and July 2018.

What organisations can take from it

A new monitoring system is no substitute for oversight: whether its alerts are actually reviewed must be checked continuously.

Relevance to training and awareness

Handling of transaction monitoring alerts

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), 19(3), 12(3) und 12(5) Schedule 2 AMLO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
The bank identified and reported the deficiencies itself, took remedial measures, had no previous disciplinary record under the AMLO and cooperated in the proceedings.
Published
19 Apr 2024

Original amount 9,000,000 HKD, converted at the ECB reference rate of 19 Apr 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 19 Apr 2026 · Direct link

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19 Apr 2024 a Canadian securities dealer and portfolio managerFINTRAC: CAD 49,500 penalty on securities dealer for 2 violations of anti-money laundering obligations CanadaInternal controlsanonymised €33,752

According to FINTRAC, the company is a securities dealer or wealth management firm. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 49,500 on the company on 19 April 2024. According to FINTRAC's findings, made during a compliance examination in 2022, the company committed 2 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures and assessing and documenting money laundering and terrorist financing risks. According to FINTRAC, the penalty has been paid in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTF Regulations 71(1)(b), 71(1)(c); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
31 Jul 2024

Original amount 49,500 CAD, converted at the ECB reference rate of 19 Apr 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 19 Apr 2026 · Direct link

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11 Apr 2024 a UK authorised fund managerFCA: fund management company required to pay around £298m to fund investors United KingdomOrganisational requirementsanonymised Order

The FCA required a UK authorised fund manager to pay restitution of up to £298,403,919 to a suspended UK equity income fund for the benefit of investors. The FCA found that, as the fund's authorised corporate director, the firm failed between July 2018 and the fund's suspension in June 2019 to monitor liquidity adequately and to supervise the investment manager properly, disadvantaging investors who did not redeem in time. The FCA did not impose a fine, which it said would otherwise have been £50 million, because payment is made through a court-approved scheme of arrangement.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
FCA Principles 2 und 6; section 384(1) FSMA 2000 (Restitution)
Action
Order
Status of proceedings
final
Sector
Financial services and insurance

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 11 Apr 2026 · Direct link

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9 Apr 2024 a major Canadian bankFINTRAC: CAD 9,185,000 penalty on major Canadian bank for 5 violations of anti-money laundering obligations CanadaSuspicious activity reportsanonymised €6.23m

According to FINTRAC, the company is a bank based in Toronto, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 9,185,000 on the company on 9 April 2024. According to FINTRAC's findings, made during a compliance examination in 2023, the company committed 5 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, assessing and documenting money laundering and terrorist financing risks, enhanced measures for high-risk situations and ongoing monitoring of business relationships. Specifically, FINTRAC found 20 missing suspicious transaction reports in 178 case files reviewed; the bank also exercised insufficient oversight of its client risk rating during a system transition, so that 85 clients were not subject to the required special measures and in 96 cases no reassessment and monitoring was documented. FINTRAC stresses that the penalty was imposed for administrative violations and not for money laundering or terrorist financing offences. According to FINTRAC, the penalty has been paid in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 6, 7, 9.6(3); PCMLTF Regulations 123.1, 146(1), 156(1)(c), 156(2), 157; PCMLTF Suspicious Transaction Reporting Regulations s. 9(1); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
2 May 2024

Original amount 9,185,000 CAD, converted at the ECB reference rate of 9 Apr 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 9 Apr 2026 · Direct link

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28 Mar 2024 a Swiss private bankPrivate bank fined CHF 750,000 for organisational failings over money laundering SwitzerlandInternal controlsanonymised €767,971

In the Lava Jato case complex, the Bundesanwaltschaft (BA, Office of the Attorney General of Switzerland) found that between 2011 and 2014 a Swiss private bank did not adequately establish beneficial owners and the background of transactions at its Lugano office, enabling two employees to commit money laundering exceeding USD 20 million. By summary penalty order of 28 March 2024 the bank was fined CHF 750,000; the BA dropped the charge of bribery of foreign public officials. The bank waived its right to object, so the penalty order becomes final.

What organisations can take from it

For accounts with conspicuous structures, beneficial ownership must be checked independently of the relationship manager.

Relevance to training and awareness

Establishing beneficial owners and front-man structures

Authority / court
Bundesanwaltschaft (BA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 102 Abs. 2 StGB i.V.m. Art. 305bis Ziff. 2 StGB
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The bank's cooperation with the Office of the Attorney General was taken into account.
Published
4 Apr 2024

Original amount 750,000 CHF, converted at the ECB reference rate of 28 Mar 2024.

Checked against the official source on 2 Oct 2026 · Company name anonymised since 28 Mar 2026 · Direct link

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28 Mar 2024 a South African derivatives provider and a licensed financial services providerFSCA: ZAR 11m against two financial services firms over unauthorised CFD business South AfricaOrganisational requirementsanonymised €535,994

Between 2020 and 2022, a South African derivatives provider, acting as representative of a licensed financial services provider, offered over-the-counter derivatives (CFDs) without authorisation, transacted in its own name and wrongly named a clearing provider on its website; the financial services provider failed to supervise its representative. The FSCA imposed ZAR 10m on the derivatives provider and ZAR 1m on the financial services provider (ZAR 11m in total), together with enforceable undertakings, including withdrawal of the derivatives provider's licence application and an external audit and compliance officer at the financial services provider.

What organisations can take from it

A licensed financial services provider is answerable for its representatives' business and must check whether their offering is covered by its own licence.

Relevance to training and awareness

Licence limits and supervision of representatives in financial distribution

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Financial Markets Act 2012, Regulation 2; FAIS Act 37 of 2002, ss. 8(9)(c), 13(1)(c), 13(2)(a)(b); General Code of Conduct ss. 2, 11; Financial Sector Regulation Act 9 of 2017, s. 139
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The parties complied with the earlier FSCA directive without delay and cooperated; the financial services provider had a long track record without previous findings.
Liability of senior managers
Measures against individuals are not set out here.
Published
28 Mar 2024

Original amount 11,000,000 ZAR, converted at the ECB reference rate of 28 Mar 2024.

Checked against the official source on 14 Oct 2026 · Company name anonymised since 28 Mar 2026 · Direct link

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26 Mar 2024 a South African credit bureauInformation Regulator: order against a credit bureau over inadequate access control South AfricaData breaches and data securityanonymised Order

Following a security compromise reported in March 2022, the Information Regulator found that the credit bureau had failed to secure the confidentiality of the data, had not implemented its own access policies and had allowed unauthorised actors in through compromised credentials and a weak password. By enforcement notice it was ordered to put security measures in place, have a qualified auditor check all user accounts against its SFTP user creation policy and carry out a personal information impact assessment; the deadline for proof was 26 May 2024.

What organisations can take from it

User creation and access management policies only protect if compliance with them is monitored technically; compromised credentials and weak passwords are a way in.

Relevance to training and awareness

Access management and password security

Authority / court
Information Regulator (South Africa)
Area of law
Data protection · Data breaches and data security
Legal basis
Protection of Personal Information Act 4 of 2013 (POPIA), Bedingungen für die rechtmäßige Verarbeitung (Sicherheitsmaßnahmen); Enforcement Notice
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Published
26 Mar 2024

Checked against the official source on 8 Oct 2026 · Company name anonymised since 26 Mar 2026 · Direct link

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25 Mar 2024 a Swiss bankFINMA confiscates 3.9 million CHF in profits from Swiss bank SwitzerlandSuspicious activity reportsanonymised €4.01m

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

What organisations can take from it

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

Relevance to training and awareness

PEP clarifications and openness towards the supervisory authority

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

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

Sources

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20 Mar 2024 a German credit rating agencyCredit rating agency: conflicts of interest not identified and disclosed – 2.2 million EUR EU levelOrganisational requirementsanonymised €2.2m

The credit rating agency lacked adequate procedures, internal controls and organisational arrangements to deal with conflicts of interest, did not disclose a potential conflict and concealed ancillary services it had provided to a rated entity. ESMA found negligent infringements and imposed fines of 2,197,500 EUR.

What organisations can take from it

Systematically record and disclose ancillary services for customers whom you are at the same time rating or auditing.

Relevance to training and awareness

Identifying and disclosing conflicts of interest

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), Anhang III
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Repeat case
yes
Published
22 Mar 2024

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 20 Mar 2026 · Direct link

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18 Mar 2024 a Portuguese payments groupPortugal: €13.87m fine for payments group for tying payment-system access to processing PortugalAbuse of market poweranonymised €13.9m

The competition authority fined the payments group 13,869,000 EUR because card issuers and acquirers could only access the group's domestic payment systems (including the national card scheme, a mobile payment solution and the ATM network) if they also bought its processing services. The authority found that this tying, which lasted about three years, was an abuse of a dominant position that held back rival payment processors; the addressees were the holding company and three subsidiaries of the group.

What organisations can take from it

A company that controls indispensable infrastructure must not make access conditional on buying its other services.

Relevance to training and awareness

Tying and access to infrastructure by dominant undertakings

Authority / court
Autoridade da Concorrência (AdC)
Area of law
Competition law · Abuse of market power
Legal basis
Art. 11 Lei n.º 19/2012 (Lei da Concorrência); Art. 102 AEUV
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
19 Mar 2024

Checked against the official source on 28 Sep 2026 · Company name anonymised since 18 Mar 2026 · Direct link

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18 Mar 2024 a US investment adviserSEC ‘AI washing’: investment adviser pays 225,000 US dollars for fabricated AI use USAAI systemsanonymised €206,574

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

What organisations can take from it

Statements about the use of AI in marketing and investor information must be technically verifiable.

Relevance to training and awareness

Permissible advertising claims about AI capabilities

Authority / court
U.S. Securities and Exchange Commission
Area of law
AI and digital regulation · AI systems
Legal basis
Investment Advisers Act of 1940; Marketing Rule
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
18 Mar 2024

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

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 18 Mar 2026 · Direct link

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18 Mar 2024 a US investment adviserSEC ‘AI washing’: investment adviser pays 175,000 US dollars for AI advertising promises USAAI systemsanonymised €160,668

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

What organisations can take from it

Superlatives such as ‘first AI adviser’ are statements of fact and must be checked before publication.

Relevance to training and awareness

Permissible advertising claims about AI capabilities

Authority / court
U.S. Securities and Exchange Commission
Area of law
AI and digital regulation · AI systems
Legal basis
Investment Advisers Act of 1940; Marketing Rule
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
18 Mar 2024

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

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 18 Mar 2026 · Direct link

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14 Mar 2024 a Swiss private banking groupOFAC: USD 3.74 million settlement with Swiss private banking group over securities transactions for customers in Cuba and blocked persons USABreaches of sanctions and embargoesanonymised €3.42m

A Swiss private banking group is paying USD 3,740,442 under a settlement with OFAC for apparent violations of multiple sanctions programmes; USD 1,000,000 of this is suspended pending completion of certain compliance commitments. According to OFAC's findings, between 2014 and 2018 entities of the group caused US securities firms to process 727 securities transactions worth USD 29,939,701 for customers in Cuba and 141 transactions worth USD 468,615 for a person blocked under the Kingpin Act; in 2023 five dividend payments to a person blocked under the Russia sanctions followed. In total 873 transactions worth USD 30,409,488 were involved. OFAC treated the apparent violations as voluntarily self-disclosed and non-egregious; the base penalty was USD 10,686,977. Summarised in our own words.

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
Cuban Assets Control Regulations, 31 C.F.R. § 515.201; Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. § 598.202; Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. § 587.201; Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
14 Mar 2024

Original amount 3,740,442 USD, converted at the ECB reference rate of 14 Mar 2024.

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12 Mar 2024 a Polish major bankPolish major bank: 1.44 million PLN – stolen customer documents not reported PolandIncident reporting obligationsanonymised €336,066

A courier consignment containing bank documents (including PESEL numbers, account numbers, login credentials) was stolen and discarded on a housing estate; the supervisory authority learned of it from the media. The bank had informed neither the authority nor the data subjects because it rated the risk as low – it had already been sanctioned in 2022 for failing to notify data subjects.

What organisations can take from it

Assess the risk of a data breach from the data subjects’ perspective – failing to notify the loss of sensitive documents risks a higher penalty than the breach itself.

Relevance to training and awareness

Risk assessment and notification of data breaches

Authority / court
Prezes Urzędu Ochrony Danych Osobowych (UODO)
Area of law
Information security and cyber · Incident reporting obligations
Legal basis
Art. 33 Abs. 1, Art. 34 Abs. 1 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Repeat case
yes
Published
2 Apr 2024

Original amount 1,440,549 PLN, converted at the ECB reference rate of 12 Mar 2024.

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12 Mar 2024 a Polish bank belonging to a car manufacturerPolish bank: 78,575 PLN – misdirected mailing reported only after 1.5 years PolandIncident reporting obligationsanonymised €18,331

The bank sent a customer’s contract data to the wrong recipient and only reported the breach one and a half years later, when the supervisory authority made enquiries following a complaint. Given the risk of identity theft, the authority considered that there had been an obligation to notify within 72 hours.

What organisations can take from it

Even a single misdirected mailing containing identity data is notifiable – misdirected mail cases need a documented risk assessment.

Relevance to training and awareness

Recognising misdirected mail and reporting it internally

Authority / court
Prezes Urzędu Ochrony Danych Osobowych (UODO)
Area of law
Information security and cyber · Incident reporting obligations
Legal basis
Art. 33 Abs. 1 DSGVO
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
2 Apr 2024

Original amount 78,575.4 PLN, converted at the ECB reference rate of 12 Mar 2024.

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11 Mar 2024 a German major bankBaFin fines a major bank €1.45m for supervisory failings in AML compliance GermanyCustomer due diligenceanonymised €1.45m

BaFin (German Federal Financial Supervisory Authority) imposed two fines of 375,000 EUR and 1,075,000 EUR, 1,450,000 EUR in total, on a German major bank, also as universal successor of a direct bank merged into it. Owing to inadequate supervision, employees had not updated customer data on time or sufficiently, internal safeguards were inadequate, and enhanced due diligence was insufficiently applied in three cases. The decision of 11 March 2024 has been final since 28 March 2024.

What organisations can take from it

Work instructions on updating customer data are only sufficient if management effectively monitors compliance with them.

Relevance to training and awareness

Updating customer data regularly and applying enhanced due diligence

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 130 Abs. 1 OWiG i. V. m. § 56 Abs. 1 S. 1 Nr. 3, Nr. 20, Nr. 32, Nr. 34 und Nr. 35 GwG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
The fine punished a breach of the duty of supervision within the company (§ 130 OWiG, German Administrative Offences Act): inadequate oversight enabled the employees' breaches.
Published
22 Apr 2024

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11 Mar 2024 a UK financial advice firm (in administration)FCA: £897,840 fine for financial adviser over pension transfer advice United KingdomConsumer protection and online retailanonymised €1.05m

The FCA fined a UK financial advice firm £897,840, of which £740,140 is disgorgement. The FCA found that between June 2015 and December 2017 the firm advised 307 customers, mostly members of the British Steel Pension Scheme, on transferring out of defined benefit pensions and often recommended a transfer without a reasonable basis. It frequently failed to gather enough information on customers' finances, and in the FCA's view some reports were misleading. Because the firm is in administration, the FCA ranks its claim behind valid creditors.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Consumer protection and online retail
Legal basis
Principle 9, COBS 9.2.1R, 9.2.2R, 9.2.3R, 9.2.6R, 9.4.1R, 9.4.7R, 19.1.2R; Principle 6, COBS 4.2.1R; Principle 3, SYSC 3.1.1R, 3.2.6R; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 897,840 GBP, converted at the ECB reference rate of 11 Mar 2024.

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8 Mar 2024 a small Swiss bankFINMA revokes a small Swiss bank's licence and later opens bankruptcy proceedings SwitzerlandOrganisational requirementsanonymised Order

The bank repeatedly breached capital requirements and organisational and risk-management requirements, kept faulty accounts, breached duties to provide information and report, and despite a ban on risk-increasing business took on higher-risk client relationships without clarifying their background; the deficiencies persisted despite measures already ordered in 2022. On 8 March 2024 the Eidgenössische Finanzmarktaufsicht (FINMA, Swiss Financial Market Supervisory Authority) revoked the bank's licence and found that it no longer offered the guarantee of irreproachable business conduct; because minimum capital was clearly undershot and over-indebtedness was feared, FINMA opened bankruptcy proceedings on 13 June 2024. At that time the licence revocation was under appeal before the Federal Administrative Court.

What organisations can take from it

Supervisory requirements must be implemented on time; a firm that takes on new risks while deficiencies remain open will ultimately lose its licence.

Relevance to training and awareness

Capital, organisation and due diligence at small banks

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Bankenaufsichtsrecht: Eigenmittelvorschriften, Organisation und Risikomanagement, Sorgfaltspflichten zur Geldwäschereibekämpfung; Bewilligungsentzug
Action
Order
Status of proceedings
under appeal
Sector
Financial services and insurance
Employees
50 to 249
Repeat case
yes
Published
13 Jun 2024
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7 Mar 2024 a Czech bankČNB: CZK 8m fine for a bank – misuse reporting not available at all times after merger CzechiaConsumer protection and online retailanonymised €315,470

The ČNB (Czech National Bank) fined the bank 8,000,000 CZK by way of a penalty order. After the merger with an acquired bank, 505,316 users of the inherited internet banking and 155,998 users of the mobile banking could, from 1 January to 13 November 2022, report loss, theft or misuse of their payment instrument only during the opening hours of the customer centre and branches instead of around the clock. A second sanctioned breach is redacted in the published order.

What organisations can take from it

In mergers and system migrations, round-the-clock blocking and misuse reporting for every inherited payment instrument belongs on the integration checklist.

Relevance to training and awareness

Blocking and reporting channels for compromised payment instruments

Authority / court
Česká národní banka (ČNB)
Area of law
Consumer protection and online retail
Legal basis
§ 166 Abs. 1 lit. c Nr. 1, § 231 Abs. 4 und Abs. 6 lit. d Zákon č. 370/2017 Sb. (Zahlungsverkehrsgesetz)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 8,000,000 CZK, converted at the ECB reference rate of 7 Mar 2024.

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28 Feb 2024 a South African fund managerSouth African fund manager: ZAR 16m for failings in anti-money laundering controls South AfricaInternal controlsanonymised €769,760

An inspection in October and November 2022 found that the risk management and compliance programme (RMCP) of the fund manager, a subsidiary of a banking group, was deficient, that some clients and beneficial owners had not been identified and verified, and that clients had not been screened against the UN targeted financial sanctions lists. A penalty of 16 million ZAR was imposed, of which 6 million ZAR was suspended for three years; 10 million ZAR was payable by 28 February 2024, together with a directive to remedy the remaining deficiencies.

What organisations can take from it

An anti-money laundering programme must not merely exist but must specifically cover client identification, beneficial owners and screening against sanctions lists.

Relevance to training and awareness

Customer due diligence, beneficial owners and sanctions-list screening

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Sections 42(1), 42(2), 21(1), 21B und 28A i. V. m. 26A–26C Financial Intelligence Centre Act 38 of 2001 (FIC Act)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Remedial action already taken; 6 million ZAR suspended for three years, provided the directive is fully implemented and the relevant obligations are complied with.
Published
28 Feb 2024

Original amount 16,000,000 ZAR, converted at the ECB reference rate of 28 Feb 2024.

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27 Feb 2024 an Irish investment firmCentral Bank: €1.225m fine against broker for ineffective trade surveillance (MAR) IrelandMarket abuse and insider dealinganonymised €1.23m

From July 2016 to January 2022, some five and a half years, the investment firm had no effective system to detect and report suspicious orders and transactions as required by Art. 16(2) MAR. The Central Bank imposed allegedly €1,225,000 after a 30% settlement discount (base amount €1.75m); the breach was admitted.

What organisations can take from it

Trade surveillance needs suitable parameters, trained analysts and clear escalation routes – a tool alone does not satisfy Art. 16 MAR.

Authority / court
Central Bank of Ireland
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 16(2) Verordnung (EU) Nr. 596/2014 (MAR)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
30% settlement discount; breach admitted.
Published
29 Feb 2024

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15 Feb 2024 a UK insurance intermediaryICO: GBP 80,000 fine for insurance intermediary over calls to TPS numbers United KingdomMarketing and consentanonymised €93,420

On 15 February 2024 the ICO fined a UK insurance intermediary GBP 80,000 and served an enforcement notice on the same day. According to the ICO's findings, between 5 May 2021 and 5 May 2022 the company instigated at least 47,998 unsolicited marketing calls to numbers registered with the TPS, without the subscribers having agreed to such calls, and the people called were not given the caller information required by law. The ICO treated this as a breach of regulations 21 and 24 of PECR. Under the notice, payment by 18 March 2024 reduced the fine to GBP 64,000. The ICO published the case on 7 March 2024.

Authority / court
Information Commissioner's Office (ICO)
Area of law
Data protection · Marketing and consent
Legal basis
Regulation 21 und 24 PECR; section 55A DPA 1998 (Geldbuße); section 40 DPA 1998 (Enforcement Notice, Regulation 21 PECR)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 80,000 GBP, converted at the ECB reference rate of 15 Feb 2024.

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11 Feb 2024 a money services business based in British ColumbiaFINTRAC: CAD 315,282 penalty on money services business for 6 violations of anti-money laundering obligations CanadaSuspicious activity reportsanonymised €217,646

According to FINTRAC, the company is a money services business based in Richmond, British Columbia. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 315,282 on the company on 11 February 2024. According to FINTRAC's findings, made during a compliance examination in 2022, the company committed 6 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting, large cash transaction reporting, international electronic funds transfer reporting, written compliance policies and procedures and assessing and documenting money laundering and terrorist financing risks. Specifically, for 2020 and 2021 FINTRAC found two missing suspicious transaction reports, three unfiled reports of cash receipts of CAD 10,000 or more, and 25 outgoing and four incoming international transfers that were not reported; the client risk assessment was not applied in practice. According to FINTRAC, the penalty has been paid in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9(1), 9.6(1); PCMLTF Regulations 28(1)(a), 28(1)(b), 28(1)(c), 71(1)(b), 71(1)(c); PCMLTF Suspicious Transaction Reporting Regulations s. 9(1); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
12 Sep 2024

Original amount 315,282 CAD, converted at the ECB reference rate of 9 Feb 2024.

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8 Feb 2024 an Italian major bankGarante: €2.8m fine for major bank after mobile banking data leak ItalyData breaches and data securityanonymised €2.8m

In a massive attack on the mobile banking portal in October 2018, attackers obtained the name, tax code and internal customer identifier of around 778,000 customers and former customers, and for more than 6,800 of them also the PIN, because the system returned these data even when a login failed. The Garante (Italian data protection authority) imposed a fine of 2,800,000 EUR because the bank had not taken effective protective measures against such attacks and had allowed weak PINs. According to the Garante, the Tribunale di Milano (Milan court) dismissed the bank's challenge by a judgment of July 2026.

What organisations can take from it

Login interfaces must not disclose customer data on failed attempts, and weak PINs must be ruled out technically.

Relevance to training and awareness

Secure authentication and weak PINs

Authority / court
Garante per la protezione dei dati personali
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 5 Abs. 1 lit. f und Art. 32 Abs. 1 und 2 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Repeat case
yes
Mitigating circumstances
Mitigating: prompt remedial measures, information and support for customers, no banking data affected.
Published
7 Mar 2024

Checked against the official source on 28 Sep 2026 · Company name anonymised since 8 Feb 2026 · Direct link

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8 Feb 2024 a German major bankBaFin fines a major bank €50,000 for flawed reporting of an IT security incident GermanyIncident reporting obligationsanonymised €50,000

BaFin (German Federal Financial Supervisory Authority) imposed a fine of 50,000 EUR on a German major bank because the bank had given it incorrect information about a major customer-relevant IT security incident affecting its payment services in 2023 and had informed it considerably late. The decision of 8 February 2024 is final.

What organisations can take from it

IT incident reports must be fast and accurate; incorrect information given to the supervisor is sanctioned in its own right.

Relevance to training and awareness

Reporting major IT security incidents correctly and on time

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Information security and cyber · Incident reporting obligations
Legal basis
§ 64 Abs. 3 Nr. 15 ZAG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
18 Mar 2024

Checked against the official source on 2 Oct 2026 · Company name anonymised since 8 Feb 2026 · Direct link

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6 Feb 2024 a German digital bankBaFin fines a digital bank €6.5m for systematically late suspicious activity reports GermanySuspicious activity reportsanonymised €6.5m

BaFin (Bundesanstalt für Finanzdienstleistungsaufsicht, German Federal Financial Supervisory Authority) imposed a fine of 6,500,000 EUR on a German digital bank because the institution had systematically filed money laundering suspicious activity reports with the Financial Intelligence Unit (FIU) too late. The decision of 6 February 2024 is final.

What organisations can take from it

Anyone who lets suspicious activity reports slip risks fines in the millions; reporting processes need sufficient capacity and effective deadline control.

Relevance to training and awareness

Reporting suspicious cases to the FIU 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
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
7 Mar 2024

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6 Feb 2024 a UAE insurance agencyCBUAE revokes licence of an insurance agency over weak compliance United Arab EmiratesOrganisational requirementsanonymised Other

The Central Bank of the UAE (CBUAE) revoked the licence of the insurance agency and struck it off the register. The reasons were a weak compliance framework and failure to meet regulatory obligations; the legal basis was Article 20 of Resolution No. 08 of 2011 on the regulation of insurance agents' business.

What organisations can take from it

Intermediaries also need a working compliance framework – without one, the regulator can revoke the licence.

Relevance to training and awareness

Compliance frameworks at insurance intermediaries

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 20 Resolution No. 08 of 2011 Concerning the Regulation of Insurance Agents Business
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
6 Feb 2024

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29 Jan 2024 two UK entities of a major banking groupPRA: £57.4m fine on major bank for failings in depositor protection data United KingdomOrganisational requirementsanonymised €67.4m

The PRA fined two UK entities of the banking group 57,417,500 GBP because for years both failed to implement the Depositor Protection Rules properly and did not reliably provide the data the FSCS deposit guarantee scheme needs to pay out. Among other things, one of the two entities wrongly marked 99% of its eligible beneficiary deposits as not protected, gave the PRA an incorrect attestation and did not inform it of identified problems for around 15 months; the PRA considered that this also undermined its preparation for resolution (first case under Fundamental Rule 8).

What organisations can take from it

Depositor protection and resolution data need a clearly accountable senior manager, and identified errors must be reported to the regulator at once.

Relevance to training and awareness

Data quality for depositor protection and resolution; openness with the regulator

Authority / court
Prudential Regulation Authority (PRA), Bank of England
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
PRA Fundamental Rules 2, 6, 7 und 8; Depositor Protection Rules 11, 12, 14 und 50 (PRA Rulebook); s. 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Culpability
negligent
Mitigating circumstances
Cooperation including early admissions (15% reduction) and settlement (a further 30%); 96.5 million GBP without the reductions; in the PRA's view the breaches were neither deliberate nor reckless.
Published
30 Jan 2024

Original amount 57,417,500 GBP, converted at the ECB reference rate of 29 Jan 2024.

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29 Jan 2024 an Estonian bankEstonia: order against a bank over shortcomings in credit risk management EstoniaOrganisational requirementsanonymised Order

Following an on-site inspection, the Finantsinspektsioon (Estonian Financial Supervision Authority) required the bank by an order (ettekirjutus) of 29 January 2024 to remedy shortcomings in the management and control of credit risk, including in its impairment methodology. The inspection had also found that several internal rules did not meet the requirements and that existing rules were not always followed.

What organisations can take from it

Internal credit policies only protect a bank if compliance and internal audit regularly check that they are followed.

Authority / court
Finantsinspektsioon (Estnische Finanzaufsicht)
Area of law
Capital markets and financial supervision · Organisational requirements
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Published
29 Jan 2024

Checked against the official source on 28 Sep 2026 · Company name anonymised since 29 Jan 2026 · Direct link

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16 Jan 2024 a large US broker-dealerSEC: broker-dealer pays 18 million US dollars over gagging clauses in client settlements USARetaliation against whistleblowersanonymised €16.5m

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

What organisations can take from it

Confidentiality clauses with clients must not exclude voluntary reporting to supervisory authorities either.

Relevance to training and awareness

Whistleblower protection in settlement and confidentiality agreements

Authority / court
U.S. Securities and Exchange Commission
Area of law
Whistleblower protection · Retaliation against whistleblowers
Legal basis
Securities Exchange Act of 1934, Rule 21F-17(a)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
16 Jan 2024

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

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16 Jan 2024 an Estonian pension fund managerEstonia: pension fund manager fined over deficient fund advertising EstoniaMisleading advertising and pricinganonymised €17,500

The Finantsinspektsioon (Estonian Financial Supervision Authority) fined a pension fund manager 100,000 EUR because fund advertisements published from 20 to 31 July 2023 lacked mandatory notices (to the terms, to expert advice and to the prospectus and key information) and in part conveyed an apparent assurance of returns or were misleading. According to the authority's announcement of 19 November 2024, the Harju Maakohus (Harju County Court) upheld the breach but, as there were no previous penalties, reduced the fine to 17,500 EUR.

What organisations can take from it

Advertising for financial products needs a pre-publication check of mandatory notices and return statements, even for short campaigns.

Relevance to training and awareness

Mandatory disclosures and approval process for financial advertising

Authority / court
Finantsinspektsioon (Estnische Finanzaufsicht)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
§ 482 Abs. 2 Investeerimisfondide seadus (IFS); Reklaamiseadus
Action
Fine
Status of proceedings
reduced
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
The court took into account that there were no previous penalties and no apparent risk of repetition, and reduced the fine.
Published
16 Jan 2024

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11 Jan 2024 a UK company sending debt advice marketing textsICO: GBP 50,000 fine for text marketer over unsolicited debt help texts United KingdomMarketing and consentanonymised €58,042

On 11 January 2024 the ICO fined the company GBP 50,000 and served an enforcement notice on the same day. According to the ICO's findings, between 14 March and 30 April 2022 the company sent 49,938 marketing text messages promoting debt advice and debt solutions, 31,329 of which were delivered, without valid consent and without identifying the sender. The ICO treated this as a breach of regulations 22 and 23 of PECR. Under the notice, payment by 12 February 2024 reduced the fine to GBP 40,000. The ICO published the case on 19 January 2024.

Authority / court
Information Commissioner's Office (ICO)
Area of law
Data protection · Marketing and consent
Legal basis
Regulation 22 und 23 PECR; section 55A DPA 1998 (Geldbuße); section 40 DPA 1998 (Enforcement Notice)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 50,000 GBP, converted at the ECB reference rate of 11 Jan 2024.

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10 Jan 2024 a Luxembourg life insurerLuxembourg life insurer: 1.68 million EUR over missing overall money laundering risk assessment LuxembourgInternal controlsanonymised €1.68m

During an inspection in 2021/2022, the Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) found that the life insurer had not prepared an overall assessment of its money laundering risks, that guidance for employees on due diligence obligations (beneficial owners, high-risk countries, PEPs) was inadequate and that it was not checked whether the intermediaries used fulfilled their due diligence obligations. It imposed 1,682,000 EUR.

What organisations can take from it

Without a documented overall risk assessment, a risk-based approach cannot be demonstrated – intermediaries must also be monitored.

Relevance to training and awareness

Due diligence obligations regarding beneficial owners and PEPs

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Loi modifiée du 12 novembre 2004 (LBC/FT), Art. 2-1, 2-2, 8-4, 8-5; Règlement CAA 20/03
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
20 Mar 2024

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 10 Jan 2026 · Direct link

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28 Dec 2023 a Swiss major bankSwiss major bank: 3.9 million SGD as relationship managers concealed excessive spreads SingaporeOrganisational requirementsanonymised €2.66m

Relationship managers at the Singapore branch gave clients false or incomplete post-trade disclosures on 39 over-the-counter bond transactions, so that the clients paid spreads above the agreed rates. On 28 December 2023 the Monetary Authority of Singapore (MAS, Singapore's central bank and financial regulator) imposed a civil penalty of 3.9 million SGD on the bank because it lacked adequate controls, such as post-trade monitoring, to prevent or detect the misconduct. The bank admitted liability, paid immediately and separately compensated the affected clients.

What organisations can take from it

Banks must monitor their relationship managers' post-trade pricing disclosures, or they will be liable themselves for the misconduct.

Relevance to training and awareness

Fair and transparent pricing disclosures in private banking

Authority / court
Monetary Authority of Singapore (MAS)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Securities and Futures Act 2001, s 236C i. V. m. ss 201(c), 201(d); Civil Penalty nach s 232 SFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Culpability
negligent
Mitigating circumstances
Liability admitted, penalty paid immediately, affected clients compensated and internal controls strengthened.
Published
28 Dec 2023

Original amount 3,900,000 SGD, converted at the ECB reference rate of 28 Dec 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 28 Dec 2025 · Direct link

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26 Dec 2023 a brokerage firm in the DIFCDFSA: USD 1.37m on brokerage firm for inadequate compliance resources United Arab EmiratesOrganisational requirementsanonymised €1.24m

After acquiring a further brokerage business the broker lacked sufficient compliance resources, although senior management knew of the shortfall; the DFSA also found breaches regarding the timing of customer due diligence and the recording of communications (July 2020 to November 2022). Because of a settlement and an Enforceable Undertaking with an external compliance expert, the fine was reduced from USD 2,793,403 to USD 1,368,767.

What organisations can take from it

A firm growing through acquisitions must plan compliance capacity in advance – failing to fix known shortfalls is itself a breach.

Relevance to training and awareness

Compliance resources after acquisitions and growth

Authority / court
Dubai Financial Services Authority (DFSA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 90(2)(a) Regulatory Law 2004 (DIFC); GEN Rules 4.2.4, 5.3.1, 5.3.9, 5.3.11; AML Rule 7.2.1; COB Rule 6.7.1 DFSA Rulebook
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Settlement and Enforceable Undertaking; no evidence of deliberate contraventions; fine reduced from USD 2,793,403 to USD 1,368,767.
Liability of senior managers
Senior management knew of the compliance staffing shortfall and did not address it; the source mentions no sanctions against individuals.
Published
29 Dec 2023

Original amount 1,368,767 USD, converted at the ECB reference rate of 22 Dec 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 26 Dec 2025 · Direct link

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26 Dec 2023 four major Japanese insurersFour major Japanese insurers: orders over coordinated premiums in commercial insurance JapanOrganisational requirementsanonymised Order

The four non-life insurers received business improvement orders under Art. 132(1) of the Insurance Business Act because, mainly in co-insurance for corporate clients, they had coordinated premiums and terms among themselves or via agencies, which in the authority’s view is likely to breach the Antimonopoly Act. By 26 December 2023, 576 affected policyholders had been reported; 33% of the cases were committed in the knowledge that they were improper, specific competition law rules of conduct were lacking and training on the subject was inadequate. The orders required further investigation, a competition law compliance organisation and clarification of management responsibility.

What organisations can take from it

Where competitors inevitably interact in co-insurance, sales staff need specific rules and training on what information may be shared.

Relevance to training and awareness

Competition-law-compliant dealings with competitors and agencies

Missing or inadequate training played a role in the decision.

Authority / court
Financial Services Agency (FSA, 金融庁)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Insurance Business Act (保険業法) Art. 132 Abs. 1; Bezug zum Antimonopoly Act (独占禁止法)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Published
26 Dec 2023

Checked against the official source on 8 Oct 2026 · Company name anonymised since 26 Dec 2025 · Direct link

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21 Dec 2023 a Spanish consumer credit bankBanco de España: €2.7m fine on Spanish consumer credit bank over revolving credit cards SpainInformation duties in online retailanonymised €2.7m

The Banco de España (Spanish central bank and banking supervisor) imposed two fines totalling 2,700,000 EUR (1,800,000 and 900,000 EUR after a 40% reduction) on the bank. Between June 2018 and June 2019 the bank breached information duties in marketing credit cards, in calculating interest under the revolving repayment option and in interest and fee statements, and did not properly provide or draft pre-contractual and contractual documents for consumer credit.

What organisations can take from it

For revolving credit cards, the interest mechanism, costs and contract documents must be provided clearly and completely before the contract is concluded.

Relevance to training and awareness

Transparency in revolving credit

Authority / court
Banco de España
Area of law
Consumer protection and online retail · Information duties in online retail
Legal basis
Art. 93.f) und 98.1.b) Ley 10/2014 de ordenación, supervisión y solvencia de entidades de crédito i. V. m. Orden 2899/2011 und Circular 5/2012 del Banco de España; Art. 34.2 Ley 16/2011 de contratos de crédito al consumo; Art. 85 Ley 39/2015
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Both fines were reduced by 40% under Art. 85 Ley 39/2015 (Spanish Administrative Procedure Act).
Published
12 Aug 2024

Checked against the official source on 28 Sep 2026 · Company name anonymised since 21 Dec 2025 · Direct link

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21 Dec 2023 a Liechtenstein financial institutionLiechtenstein: CHF 500,000 fine for risk management and due diligence breaches LiechtensteinOrganisational requirementsanonymised €530,110

The Finanzmarktaufsicht (FMA, Liechtenstein Financial Market Authority) fined an unnamed legal person CHF 500,000 for a serious breach of the risk management rules under the Bankengesetz (Banking Act) and a repeated breach of the due diligence obligation to establish or update the business relationship profile. The FMA only publishes final sanctions and gives no further details of the facts.

What organisations can take from it

Business profiles must be fully established and kept up to date for every business relationship; repeated deficiencies combined with weak risk management lead to high fines.

Relevance to training and awareness

Risk management and up-to-date business profiles under due diligence law

Authority / court
Finanzmarktaufsicht Liechtenstein (FMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 63a Abs. 1 Bst. b Bankengesetz (BankG); Art. 31 Abs. 1 Bst. e Sorgfaltspflichtgesetz (SPG)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 500,000 CHF, converted at the ECB reference rate of 21 Dec 2023.

Checked against the official source on 28 Sep 2026 · Company name anonymised since 21 Dec 2025 · Direct link

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21 Dec 2023 a New York insurerOFAC: USD 466,200 settlement with US insurer over policies for a blocked company USABreaches of sanctions and embargoesanonymised €424,474

An insurer based in New York State is paying USD 466,200 under a settlement with OFAC for 39 apparent violations of the Ukraine-/Russia-related sanctions. According to OFAC's findings, between May 2018 and July 2020 the company processed transactions totalling USD 315,891 relating to four insurance policies of a Panamanian company owned by a person on the SDN List and therefore itself blocked. According to OFAC, it had been known within the company since 2010 that the policies covered that person's property. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 666,000. Summarised in our own words.

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. § 589.201(a)(4)(iii) (39 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
21 Dec 2023

Original amount 466,200 USD, converted at the ECB reference rate of 21 Dec 2023.

Checked against the official source on 28 Sep 2026 · Version 5 · Company name anonymised since 21 Dec 2025 · Direct link

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21 Dec 2023 a Latvian association of motor liability insurersLatvia: 336,086 EUR fine for motor insurers’ association over entry fee LatviaCartels and collusionanonymised €336,086

The Konkurences padome (Latvian Competition Council) found that the association, which brings together all of Latvia’s compulsory motor third-party liability (OCTA) insurers, required an entry fee as a condition of membership from 2004 to May 2022 and thereby hindered new insurers from entering the OCTA market. It treated this as a restrictive decision by an association of undertakings; the fine of 373,429 EUR (4.5 % of 2022 turnover) was reduced by 10 % to 336,086 EUR following a settlement.

What organisations can take from it

Admission conditions of industry associations with compulsory membership should be reviewed for barriers to market entry.

Authority / court
Konkurences padome (Lettischer Wettbewerbsrat)
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 101 Abs. 1 AEUV
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The association fully acknowledged the infringement in the settlement procedure; the fine was reduced by 10 %.
Published
5 Jan 2024

Checked against the official source on 28 Sep 2026 · Company name anonymised since 21 Dec 2025 · Direct link

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20 Dec 2023 five Greek banks and a banking associationGreek banks and banking association fined EUR 41.8m for colluding on ATM fees GreeceCartels and collusionanonymised €41.8m

In a settlement procedure, the Epitropi Antagonismou (Hellenic Competition Commission) found in a 2023 decision that five Greek banks had, from 2018, coordinated their pricing model for cash withdrawals at ATMs (Direct Access Fee) and other bank charges and exchanged information; the banking association acted as facilitator and also refused a payment services provider membership and obstructed its participation in an interbank credit transfer system. The fines total EUR 41,756,180.10 (the five banks 12,993,482.86; 9,978,799.18; 9,110,682.91; 7,976,790.63 and 143,181.65 EUR; banking association 1,553,242.87 EUR). In addition, from 1 January 2024 the banks must cut the fee for withdrawals with other institutions' cards to caps between EUR 1.50 and EUR 2.00 and keep it there for three years; the Commission accepted the association's commitment to introduce an internal compliance programme within six months.

What organisations can take from it

Discussing future fees within an industry association is a cartel risk – pricing decisions belong solely within the firm.

Relevance to training and awareness

Exchange of information between competitors on prices and fees, including via trade associations

Authority / court
Επιτροπή Ανταγωνισμού (Hellenic Competition Commission)
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 1 ν. 3959/2011; Art. 101 AEUV; Art. 25 Abs. 1 lit. c ν. 3959/2011 (Verhaltensmaßnahme); Vergleichsverfahren nach Art. 29a ν. 3959/2011
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Fines reduced under the settlement procedure; the banking association committed to an internal compliance programme including ongoing training.
Published
21 Dec 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 20 Dec 2025 · Direct link

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18 Dec 2023 two Hungarian companies of one corporate groupCorporate group: HUF 1.44bn for unauthorised deposit-taking disguised as vouchers HungaryCapital markets and financial supervisionanonymised €3.74m

Without authorisation from the MNB (Magyar Nemzeti Bank, central bank of Hungary), the two companies collected money from several thousand investors, disguised as purchases of shopping vouchers with a guaranteed, unrealistically high return. The MNB imposed HUF 940,000,000 on one company and HUF 500,000,000 on the other (HUF 1,440,000,000 in total), blocked websites and accounts and filed a criminal complaint.

What organisations can take from it

Anyone accepting repayable funds from the public needs supervisory authorisation, whatever the contract is called.

Relevance to training and awareness

Authorisation requirement for collecting repayable funds

Authority / court
Magyar Nemzeti Bank (MNB)
Area of law
Capital markets and financial supervision
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not reported here.
Published
18 Dec 2023

Original amount 1,440,000,000 HUF, converted at the ECB reference rate of 18 Dec 2023.

Checked against the official source on 28 Sep 2026 · Company name anonymised since 18 Dec 2025 · Direct link

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18 Dec 2023 a Hong Kong e-money providerE-money provider: reprimand and HKD 1.575m penalty for AML and governance failings Hong KongInternal controlsanonymised €185,000

The stored value facility licensee was reprimanded and must pay a pecuniary penalty of 1,575,000 HKD. From February 2019 to mid-July 2020 it lacked adequate transaction-monitoring controls under the AML guideline for SVF licensees, and from August 2016 to August 2020 it lacked sound governance, an effective risk management framework and a robust internal control system. The company therefore did not meet minimum criteria for its licence.

What organisations can take from it

Payment and e-money providers must treat transaction monitoring, governance and internal controls alike as conditions of their licence.

Relevance to training and awareness

Anti-money laundering and risk management in payment and e-money services

Authority / court
Hong Kong Monetary Authority (HKMA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
ss. 8Q, 33Q(2)(a), 33Q(2)(b)(iii) PSSVFO (Cap. 584); Schedule 3 Part 2 ss. 5(1)(d), 6(2)(b) PSSVFO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Remedial measures (some at the regulator's request), no previous disciplinary record, cooperation.
Published
18 Dec 2023

Original amount 1,575,000 HKD, converted at the ECB reference rate of 18 Dec 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 18 Dec 2025 · Direct link

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18 Dec 2023 a Dutch credit card issuerAP: €150,000 fine for a card issuer for failing to carry out a DPIA NetherlandsData protectionanonymised €150,000

The card issuer, an issuer of debit and credit cards, began re-identifying and verifying its customers online in 2019 without first carrying out a data protection impact assessment. The AP (Autoriteit Persoonsgegevens, Dutch data protection authority) found an infringement of Art. 35(1) GDPR and imposed a fine of 150,000 EUR.

What organisations can take from it

Before introducing high-risk processing such as re-identifying the entire customer base, a DPIA must be carried out and documented.

Relevance to training and awareness

Data protection impact assessment before high-risk processing

Authority / court
Autoriteit Persoonsgegevens (AP)
Area of law
Data protection
Legal basis
Art. 35 Abs. 1 DSGVO (AVG)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
16 Jan 2024

Checked against the official source on 7 Oct 2026 · Version 2 · Company name anonymised since 18 Dec 2025 · Direct link

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14 Dec 2023 three companies of an international crypto exchangeCrypto exchange: USD 1.35 billion civil monetary penalty to the CFTC over an illegal derivatives exchange and bypassed KYC duties USAOrganisational requirementsanonymised €1.24bn

On a complaint by the CFTC, the federal court in Chicago ordered three companies of an international crypto exchange, in a consent order, to pay a civil monetary penalty of 1,350,000,000 USD. Up to 500,000,000 USD of that penalty may be credited against a criminal penalty; the ordered amount remains 1,350,000,000 USD. Measures against individuals are not set out here. According to the order, the crypto exchange solicited US customers for crypto derivatives, allowed trading without customer identification through prime brokers' sub-accounts, operated the platform without registration as an exchange or futures commission merchant, had no effective customer identification and anti-money laundering programme and wilfully evaded US rules. The crypto exchange must certify the effectiveness of improved controls and set up a board with independent members as well as compliance and audit committees. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Controls that are bypassed through sub-accounts or tips to customers offer no protection; tolerated evasion is treated as a wilful breach.

Relevance to training and awareness

Circumventing KYC and anti-money laundering controls; coaching customers to evade them

Authority / court
U.S. District Court (Klage: CFTC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Sections 4(a), 4(b), 4c(b), 4d und 5h(a)(1) Commodity Exchange Act; CFTC Regulations 1.6(a), 32.2, 42.2, 48.3 und 166.3
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Liability of senior managers
Measures against individuals are not set out here.
Published
18 Dec 2023

Original amount 1,350,000,000 USD, converted at the ECB reference rate of 14 Dec 2023.

Checked against the official source on 14 Oct 2026 · Company name anonymised since 14 Dec 2025 · Direct link

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13 Dec 2023 a US crypto trading platformOFAC: USD 1.21 million settlement with US crypto platform over transactions by users in Crimea USABreaches of sanctions and embargoesanonymised €1.12m

A San Francisco crypto trading platform agreed to a settlement with OFAC of USD 1,207,830. According to OFAC's findings, between April 2020 and May 2022 the company processed 989 transactions worth around USD 1.25 million for users ordinarily resident in Crimea. Most of the 89 accounts concerned gave Russia as the country of residence but listed addresses in Crimea; screening did not pick up the address field. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 3,097,000. In view of the company's financial circumstances, USD 300,000 of the settlement amount is suspended as long as it meets its compliance commitments; a further USD 300,000 is treated as satisfied if the company invests that amount in additional sanctions controls. Summarised in our own words.

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. § 589.207 (989 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
13 Dec 2023

Original amount 1,207,830 USD, converted at the ECB reference rate of 13 Dec 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 13 Dec 2025 · Direct link

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11 Dec 2023 an Austrian bankBank deletes customer data instead of granting access: DSB fine of €9,500 AustriaData subject rights and transparencyanonymised €9,500

The DSB (Datenschutzbehörde, Austrian data protection authority) fined a bank limited by shares 9,500 EUR because it treated a customer's access request under Art. 15 GDPR internally as an erasure request, deleted her data and sent her only general information. The authority found negligence; mitigating factors were the absence of previous infringements, cooperation and insight. For the calculation the bank was placed in the turnover band of 50 to 100 million EUR.

What organisations can take from it

Data subject requests must be classified correctly before they are processed; answering an access request with erasure infringes the right of access twice over.

Relevance to training and awareness

Handling data subject access requests correctly

Authority / court
Datenschutzbehörde (DSB)
Area of law
Data protection · Data subject rights and transparency
Legal basis
Art. 12 und 15 Abs. 1 iVm Art. 83 Abs. 1 und 5 lit. b DSGVO
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
negligent
Repeat case
no
Mitigating circumstances
No previous infringements; cooperation in the proceedings, admission of the misconduct and insight.

Checked against the official source on 2 Oct 2026 · Company name anonymised since 11 Dec 2025 · Direct link

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8 Dec 2023 a US exchange operatorOFAC: USD 4.04 million settlement with US exchange operator over dealings of its former Armenian exchange subsidiary USABreaches of sanctions and embargoesanonymised €3.75m

A New York exchange operator is paying USD 4,040,923 under a settlement with OFAC for the conduct of its former Armenian subsidiary, which operated the Armenian Stock Exchange. According to OFAC's findings, between December 2012 and September 2014 the subsidiary processed 151 transactions with a face value of around USD 227.9 million on its trading platforms with the Armenian subsidiary of a designated Iranian state-owned bank, thereby knowingly exporting services to Iran and the Government of Iran. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed. Summarised in our own words.

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
Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.215 (151 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
8 Dec 2023

Original amount 4,040,923 USD, converted at the ECB reference rate of 8 Dec 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 8 Dec 2025 · Direct link

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8 Dec 2023 a South African bankPA: ZAR 10.73m against a bank over weak controls and agent-sourced clients South AfricaInternal controlsanonymised €526,866

Following an inspection in 2020, the supervisor found deficiencies in the risk management and compliance programme (including identification of beneficial owners, clients onboarded by agents and shared clients), in customer due diligence and record-keeping, in the calibration of transaction monitoring and in governance. It imposed reprimands, cautions and financial penalties totalling ZAR 10.73m (1.5m, 4m, 5m and 0.23m), of which ZAR 5m is conditionally suspended for 24 months.

What organisations can take from it

A bank that acquires clients through agents or outsources due diligence to third parties remains responsible for oversight and monitoring itself.

Relevance to training and awareness

Oversight of agents and outsourcing of due diligence duties

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Financial Intelligence Centre Act 38 of 2001, ss. 21–21H, 22–24, 42(1), 42(2), 42(2A), 42A(2), 42A(3), 45C(3); FIC Directive 5/2019
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation and remedial action; ZAR 5m conditionally suspended.
Liability of senior managers
Governance duties were also criticised, including oversight of agent relationships and remediation of known deficiencies.
Published
8 Dec 2023

Original amount 10,730,000 ZAR, converted at the ECB reference rate of 8 Dec 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 8 Dec 2025 · Direct link

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6 Dec 2023 a Latvian bankLatvia: bank pays 2.02 million EUR over anti-money-laundering failings LatviaInternal controlsanonymised €2.02m

Latvijas Banka (Bank of Latvia) concluded an administrative agreement with the bank under which the bank acknowledged breaches of the rules on preventing money laundering and terrorist and proliferation financing, accepted a fine of 2,016,342 EUR and undertook to improve its internal control system. The basis was a 2.2 million EUR fine imposed by the FKTK in 2018 that was still being challenged in court, together with inspections in 2021 and 2023 that found shortcomings in, among other things, risk management, internal audit, customer due diligence, transaction monitoring, safe-deposit risks and suspicious transaction reporting.

What organisations can take from it

Supervisory findings on anti-money-laundering controls should be acknowledged and remedied promptly before they accumulate into larger sanctions over years.

Relevance to training and awareness

Customer due diligence and suspicious activity reporting in banks

Authority / court
Latvijas Banka (Lettische Zentralbank, Finanzaufsicht)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Noziedzīgi iegūtu līdzekļu legalizācijas un terorisma un proliferācijas finansēšanas novēršanas likums; Verwaltungsvertrag (administratīvais līgums)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The bank acknowledged the breaches, had taken remedial measures and drawn up a plan to improve its control system; this was the precondition for the agreement and the reduced fine. It also undertook to ask the court to discontinue its proceedings against the 2018 FKTK decision.
Published
6 Dec 2023

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5 Dec 2023 a Spanish bankEUR 17.6m fine on a Spanish bank for failing to file a suspicious transaction report SpainSuspicious activity reportsanonymised €17.6m

The Consejo de Ministros (Spanish Council of Ministers) imposed a fine of 17,601,000 EUR and a public reprimand on a Spanish bank that has since been absorbed by another institution. The bank had not filed a suspicious transaction report although indications of money laundering or terrorist financing had been raised internally, and it had also breached the duty to examine unusual transactions with special care. The decision is not final.

What organisations can take from it

Internal suspicion reports from staff must be examined promptly and passed on to the financial intelligence unit; sitting on such reports is punished as a very serious infringement.

Relevance to training and awareness

Handling internal money laundering suspicion reports

Authority / court
Consejo de Ministros (auf Vorschlag der Comisión de Prevención del Blanqueo de Capitales e Infracciones Monetarias)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Art. 51.1.a) i. V. m. Art. 18 sowie Art. 52.1.g) i. V. m. Art. 17 Ley 10/2010 de prevención del blanqueo de capitales y de la financiación del terrorismo; Art. 56
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Employees
10,000 or more
Published
20 Dec 2025
Sources

Checked against the official source on 28 Sep 2026 · Company name anonymised since 5 Dec 2025 · Direct link

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30 Nov 2023 a bank in South AfricaBank in South Africa: ZAR 19.75m for failings in customer due diligence and reporting South AfricaCustomer due diligenceanonymised €960,122

Following a 2020 inspection, the supervisor identified failings at the bank in customer due diligence, cash threshold reporting, late and incomplete suspicious transaction reports, the handling of automated transaction monitoring alerts, staff training and the governance of anti-money laundering compliance. By a notice of sanction dated 30 November 2023 it imposed cautions, reprimands and penalties totalling 19.75 million ZAR, of which 9.25 million ZAR is conditionally suspended for 36 months.

What organisations can take from it

Automated transaction monitoring only helps if alerts are dealt with on time and suspicious transaction reports are filed in full.

Relevance to training and awareness

Filing suspicious transaction reports on time and in full

Missing or inadequate training played a role in the decision.

Authority / court
Prudential Authority (PA) der South African Reserve Bank
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Sections 21, 21A–21H, 28, 29 (i. V. m. Regulation 24(3)), 42, 42A und 43 Financial Intelligence Centre Act 38 of 2001; FIC Directive 5 of 2019; Sanktion nach Section 45C(3) FIC Act
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation with the supervisor and remedial action; 9.25 million ZAR suspended for 36 months. The supervisor stresses that no involvement in money laundering or terrorist financing was found.
Published
8 Dec 2023

Original amount 19,750,000 ZAR, converted at the ECB reference rate of 30 Nov 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 30 Nov 2025 · Direct link

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30 Nov 2023 three money transfer firms in GlasgowFCA: Competition fines for three money transfer firms over price coordination in Glasgow United KingdomCartels and collusionanonymised €178,654

In a decision under the Competition Act 1998, the FCA found that between 18 February and 31 May 2017 three money transfer providers coordinated exchange rates and fixed a transaction fee for transfers to Pakistan made by customers in Glasgow branches. One of them, an intermediary without its own Glasgow branch, facilitated the conduct according to the FCA. The FCA imposed fines totalling £154,300: £139,500 on the first provider (subsidiary and parent), £11,200 on the intermediary and £3,600 on the third provider. All three admitted the infringement, received a 10% settlement discount and, according to the FCA, agreed not to appeal.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Competition law · Cartels and collusion
Legal basis
section 2(1) Competition Act 1998 (Chapter I prohibition)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 154,300 GBP, converted at the ECB reference rate of 30 Nov 2023.

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30 Nov 2023 a UK subsidiary of an Irish bankICO: reprimand for UK bank over inaccurate reports to credit reference agencies United KingdomData protectionanonymised Reprimand or warning

The ICO issued a reprimand to the UK subsidiary of an Irish bank. According to the ICO's findings, between 2018 and 2020 the bank sent inaccurate data about 3,282 UK customers to credit reference agencies. The problem concerned defaulted loan accounts that had been sold to debt collectors; default status and outstanding balances were recorded incorrectly, which could affect credit profiles. The ICO found infringements of Articles 5(1)(d) and 5(2) UK GDPR. The reprimand is undated; the date follows the ICO case page.

Authority / court
Information Commissioner's Office (ICO)
Area of law
Data protection
Legal basis
Art. 5(1)(d) und 5(2) UK GDPR; Verwarnung nach Art. 58(2)(b) UK GDPR
Action
Reprimand or warning
Status of proceedings
unknown
Sector
Financial services and insurance
Sources

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28 Nov 2023 a small Irish investment fundCentral Bank: €192,500 fine against investment fund for EMIR reporting gaps IrelandDisclosure and reporting obligationsanonymised €192,500

Between January 2018 and May 2020 a sub-fund failed to report a total of 200,640 derivative trades to a trade repository, as required by Art. 9(1) EMIR. The Central Bank issued a reprimand and imposed allegedly €192,500 after a 30% discount (base amount €275,000) – according to the Central Bank, the first monetary penalty imposed on an investment fund.

What organisations can take from it

Outsourced reporting obligations remain with the fund; who reports must be clearly agreed between all parties and monitored.

Authority / court
Central Bank of Ireland
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 9(1) Verordnung (EU) Nr. 648/2012 (EMIR); European Union (European Markets Infrastructure) Regulations 2014
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
Under 50
Mitigating circumstances
Settlement with a 30% discount; breach admitted.
Published
30 Nov 2023

Checked against the official source on 7 Oct 2026 · Version 2 · Company name anonymised since 28 Nov 2025 · Direct link

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27 Nov 2023 a US title insurerNYDFS: $1 million against US title insurer over open document links USA, NYSecurity measures and risk managementanonymised €913,159

An application of the insurer generated links to transaction documents without login and without an expiry date; according to a journalist, by changing the sequential document number, 885 million documents containing, among other things, social security and bank data could be retrieved. Users were told not to send sensitive data, but there were no technical barriers. The penalty was imposed by the New York State Department of Financial Services (NYDFS).

What organisations can take from it

Instructions to users do not replace technical controls – sharing links need authentication and an expiry date.

Relevance to training and awareness

Classification and sending of sensitive documents

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 §§ 500.3, 500.7 (Cybersecurity Regulation)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
negligent

Original amount 1,000,000 USD, converted at the ECB reference rate of 27 Nov 2023.

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24 Nov 2023 a Lithuanian e-money institutionE-money institution: 840,000 EUR for anti-money laundering delegated to partners without oversight LithuaniaCustomer due diligenceanonymised €840,000

The e-money institution had delegated anti-money laundering tasks to its distribution partners without monitoring them; customer profiles were often not completed, risks (including from crypto-assets) were not assessed, monitoring was insufficient and the second and third lines of defence for ICT risks were missing. Fine of 840,000 EUR, obligation to remedy the deficiencies and restriction on business expansion.

What organisations can take from it

AML duties can be delegated to distribution partners, responsibility cannot – without oversight of the partners, the institution is liable.

Authority / court
Lietuvos bankas (Litauische Zentralbank, Finanzaufsicht)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Pinigų plovimo ir teroristų finansavimo prevencijos įstatymas; IKT-Risikomanagement-Anforderungen
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The institution submitted a remediation plan and had initiated first steps.
Published
24 Nov 2023

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22 Nov 2023 a Dutch major bankMajor bank: €26.6m fine for Euro-denominated bond trading cartel EU levelCartels and collusionanonymised €26.6m

According to the European Commission's findings, traders at the bank and at another major bank exchanged sensitive information on prices, volumes and trading strategies for Euro-denominated SSA and government-guaranteed bonds via a financial data provider's terminal messages and chatrooms from 2006 to 2016 and coordinated their conduct. The bank was fined €26.6m; the other bank, as the leniency applicant that revealed the cartel, was not fined.

What organisations can take from it

Traders must not exchange prices, positions or trading strategies with competitors in chats.

Relevance to training and awareness

Information exchange between traders in chatrooms

Authority / court
Europäische Kommission
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 101 AEUV; Art. 53 EWR-Abkommen
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Published
22 Nov 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 22 Nov 2025 · Direct link

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21 Nov 2023 an international crypto exchangeOFAC: USD 968.6 million settlement with crypto exchange over matching trades between US users and users in sanctioned jurisdictions USABreaches of sanctions and embargoesanonymised €884.2m

A Cayman Islands-registered crypto exchange is paying USD 968,618,825 under a settlement with OFAC for 1,667,153 apparent violations of multiple sanctions programmes. According to OFAC's findings, from August 2017 to October 2022 its trading platform matched virtual currency trades worth around USD 706 million between US users and users in sanctioned jurisdictions or blocked persons. According to OFAC, senior management knew of and permitted the presence of US users and users from sanctioned jurisdictions on the platform, misled third parties about its controls and encouraged users to circumvent its own controls. OFAC treated the case as egregious and not voluntarily self-disclosed; the base penalty equalled the statutory maximum. The company reached parallel resolutions with the DOJ, FinCEN and the CFTC; USD 898,618,825 of the OFAC amount is deemed satisfied by the payment to the DOJ. The company must also retain an independent compliance monitor for five years. Summarised in our own words.

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
Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204; Syrian Sanctions Regulations, 31 C.F.R. § 542.207; North Korea Sanctions Regulations, 31 C.F.R. §§ 510.206, 510.212, E.O. 13722; Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. §§ 589.207, 589.213, E.O. 13685; Cuban Assets Control Regulations, 31 C.F.R. § 515.201; E.O. 14065; IEEPA § 206(a); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
21 Nov 2023

Original amount 968,618,825 USD, converted at the ECB reference rate of 21 Nov 2023.

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21 Nov 2023 a Hungarian major bankHungarian major bank: 49.4 million HUF over late suspicious transaction reports HungarySuspicious activity reportsanonymised €130,215

The bank did not report several suspicious cases to the financial intelligence unit without delay, its monitoring produced delayed hits owing to incorrectly set filter parameters, and its risk assessment, customer due diligence and documentation of anti-money laundering training showed deficiencies. The Magyar Nemzeti Bank (Central Bank of Hungary, MNB) imposed a total of 49.375 million HUF and set deadlines for remediation by August 2024.

What organisations can take from it

Validate monitoring parameters regularly – and training is expressly among the obligations that are inspected.

Relevance to training and awareness

Recognising and reporting suspected money laundering in good time

Missing or inadequate training played a role in the decision.

Authority / court
Magyar Nemzeti Bank (MNB)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Ungarisches Geldwäschegesetz (Pmt.)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Culpability
negligent
Mitigating circumstances
The bank had already initiated remedial measures for several of the infringements.
Published
21 Nov 2023

Original amount 49,375,000 HUF, converted at the ECB reference rate of 21 Nov 2023.

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15 Nov 2023 a US online lenderCFPB: online lender pays 15 million USD after breaching an earlier order USAConsumer protection and online retailanonymised €13.8m

According to the CFPB, the online lender (operating two brands) continued to debit consumer accounts without valid consent despite a 2019 order, including by using account details from purchased loan applications, and also breached the prohibition of unfair and deceptive practices. The new order supersedes the 2019 order, imposes a fine of 15 million USD and requires redress; in September 2025 the CFPB terminated it early after the fine had been paid.

What organisations can take from it

After a regulatory order, compliance must be actively monitored; a repeat breach costs many times the first sanction.

Relevance to training and awareness

Collecting customer payments only with valid authorisation

Authority / court
Consumer Financial Protection Bureau (CFPB)
Area of law
Consumer protection and online retail
Legal basis
Consumer Financial Protection Act of 2010, §§ 1031, 1036 (12 U.S.C. §§ 5531, 5536); Verstoß gegen die Consent Order 2019-BCFP-0003
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Published
15 Nov 2023

Original amount 15,000,000 USD, converted at the ECB reference rate of 15 Nov 2023.

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15 Nov 2023 an international major bankUSD/ZAR forex cartel: international major bank pays ZAR 42.7m and cooperates South AfricaCartels and collusionanonymised €2.17m

On 15 November 2023 the Competition Tribunal (South Africa's competition adjudicator) confirmed a settlement in which an international major bank admitted taking part between 2007 and 2013 in price fixing and market allocation in spot trading of the USD/ZAR currency pair, for example by coordinating bids and offers via chat platforms. The bank pays an administrative penalty of 42,715,880 ZAR, will continue its compliance programme and will provide evidence to the Competition Commission (competition authority) in its prosecution of the other banks among the 28 accused.

What organisations can take from it

Chats between traders at competing banks about prices and spreads carry a high competition law risk and belong in trading-floor surveillance and training.

Relevance to training and awareness

Competition law on trading desks: contacts between traders at competing banks

Authority / court
Competition Tribunal of South Africa (auf Antrag der Competition Commission)
Area of law
Competition law · Cartels and collusion
Legal basis
Section 4(1)(b)(i) und (ii) Competition Act 89 of 1998
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
15 Nov 2023

Original amount 42,715,880 ZAR, converted at the ECB reference rate of 15 Nov 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 15 Nov 2025 · Direct link

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14 Nov 2023 a Hungarian bankHungarian bank: HUF 62.5m after comprehensive review of governance and IT HungaryOrganisational requirementsanonymised €165,515

A group-wide inspection found shortcomings at the bank in areas including corporate governance, outsourcing notifications, internal audit, fraud prevention, credit risk monitoring, capital calculation, supervisory reporting and IT, among them the use of systems no longer supported by the vendor. The MNB (Magyar Nemzeti Bank, central bank of Hungary) imposed HUF 62,500,000 on the bank and, in a separate decision, HUF 5,500,000 on its leasing subsidiary; both must report on remediation.

What organisations can take from it

Failing to fully remedy findings from earlier inspections increases the fine at the next inspection.

Relevance to training and awareness

Outdated IT systems and incomplete internal rules as a supervisory risk

Authority / court
Magyar Nemzeti Bank (MNB)
Area of law
Capital markets and financial supervision · Organisational requirements
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
Some breaches were isolated, the bank cooperated and had taken or planned remedial measures.
Published
14 Nov 2023

Original amount 62,500,000 HUF, converted at the ECB reference rate of 14 Nov 2023.

Checked against the official source on 28 Sep 2026 · Company name anonymised since 14 Nov 2025 · Direct link

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9 Nov 2023 a UK life insurance and later-life planning providerICO: GBP 90,000 fine for a later-life planning firm over calls to TPS numbers United KingdomMarketing and consentanonymised €103,205

In November 2023 the ICO fined a UK company that sold life insurance and other later-life planning services such as funeral plans GBP 90,000 and also served an enforcement notice. According to the ICO's findings, over one year from August 2021 the company made 74,119 unsolicited marketing calls to numbers that had been registered with the TPS for at least 28 days, presenting itself under a different trading name. The ICO treated this as a breach of regulation 21 of PECR and took into account as aggravating factors, among others, a lack of cooperation and a failure to check where its data came from. Under the notice, early payment reduced the fine to GBP 72,000.

Authority / court
Information Commissioner's Office (ICO)
Area of law
Data protection · Marketing and consent
Legal basis
Regulation 21 PECR; section 55A DPA 1998 (Geldbuße); section 40 DPA 1998 (Enforcement Notice)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 90,000 GBP, converted at the ECB reference rate of 9 Nov 2023.

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8 Nov 2023 a major US bankCFPB: 25.9 million USD against major bank over credit card application discrimination USAConsumer protection and online retailanonymised €23m

According to the CFPB, from at least 2015 to 2021 the bank discriminated against credit card applicants on the basis of Armenian national origin and did not give accurate reasons for rejections, in breach of the Equal Credit Opportunity Act and Regulation B. The order required 1.4 million USD in redress and a fine of 24.5 million USD; in October 2025 the CFPB terminated it early after the payments and remedial measures had been made. The authority allegedly made the findings set out here; this account is not based on a final judgment. The amount field records only the civil monetary penalty.

What organisations can take from it

Credit decisions must never be linked to origin markers such as names or places of residence, and every rejection needs its actual reason.

Relevance to training and awareness

Non-discriminatory lending and reasons for rejections

Authority / court
Consumer Financial Protection Bureau (CFPB)
Area of law
Consumer protection and online retail
Legal basis
Equal Credit Opportunity Act (15 U.S.C. § 1691 ff.) und Regulation B; Consumer Financial Protection Act of 2010
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
8 Nov 2023

Original amount 24,500,000 USD, converted at the ECB reference rate of 8 Nov 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 8 Nov 2025 · Direct link

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7 Nov 2023 a money services business based in OntarioFINTRAC: CAD 252,285 penalty on money services business for 7 violations of anti-money laundering obligations CanadaCustomer due diligenceanonymised €171,868

According to FINTRAC, the company is a money services business based in Thornhill, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 252,285 on the company on 7 November 2023. According to FINTRAC's findings, made during a compliance examination in 2021, the company committed 7 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, compliance with a ministerial directive, record keeping, client identification and money services business registration requirements. Specifically, FINTRAC found that the company did not comply with the ministerial directive on transactions involving Iran and did not treat such transactions as high risk, that prescribed information was missing from all 32 foreign exchange tickets and all 142 transfer records reviewed, and that there was no written agreement with its agent in Iran for identity verification. According to FINTRAC, the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
PCMLTFA s. 11.43; PCMLTF Regulations 30(e), 30(f), 64.1(3), 71(1)(b), 71(1)(c); PCMLTF Registration Regulations s. 4(b), 5; Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
11 Jul 2024

Original amount 252,285 CAD, converted at the ECB reference rate of 7 Nov 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 7 Nov 2025 · Direct link

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6 Nov 2023 a US prepaid rewards payment companyOFAC: USD 206,213 settlement with payments company over redemption of reward cards in sanctioned regions USABreaches of sanctions and embargoesanonymised €191,987

An Illinois payments company is paying USD 206,213 under a settlement with OFAC for 12,391 apparent violations of the sanctions on Crimea, Iran, Syria and Cuba. According to OFAC's findings, between November 2017 and July 2022 the company, which runs prepaid reward card programmes, redeemed cards worth a total of USD 549,134.89 for recipients apparently located in those jurisdictions. Addresses were screened, but IP addresses and email suffixes were not comprehensively checked for sanctioned jurisdictions. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed; the base penalty was USD 274,950. Summarised in our own words.

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
Cuban Assets Control Regulations, 31 C.F.R. § 515.201; Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204; Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. § 589.207; Syrian Sanctions Regulations, 31 C.F.R. § 542.207; Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
6 Nov 2023

Original amount 206,213 USD, converted at the ECB reference rate of 6 Nov 2023.

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3 Nov 2023 a major Canadian bankFINTRAC: CAD 7,475,000 penalty on major Canadian bank for 3 violations of anti-money laundering obligations CanadaSuspicious activity reportsanonymised €5.1m

According to FINTRAC, the company is a bank. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 7,475,000 on the company on 3 November 2023. According to FINTRAC's findings, made during a compliance examination in 2022, the company committed 3 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting and written compliance policies and procedures. Specifically, FINTRAC found 16 missing suspicious transaction reports in 130 case files reviewed, including cases in which the bank had been served with production orders concerning clients; until May 2021 the bank also combined transactions from several branches in a single report (29 of 34 reports in a sample), and its policies gave inconsistent guidance on suspicious transaction reporting. FINTRAC stresses that the penalty was imposed for administrative violations and not for money laundering or terrorist financing offences. According to FINTRAC, the penalty has been paid in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7, 9.6(1); PCMLTF Regulations 71(1)(b); PCMLTF Suspicious Transaction Reporting Regulations s. 9(1); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
5 Dec 2023

Original amount 7,475,000 CAD, converted at the ECB reference rate of 3 Nov 2023.

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2 Nov 2023 a private bank in the DIFCDFSA: USD 373,842 on private bank for gaps in market abuse detection United Arab EmiratesMarket abuse and insider dealinganonymised €350,663

Between February 2018 and March 2021 the bank was unable to properly identify, assess and report suspicious client trading; it did not effectively supervise its outsourced trade surveillance, so trading by two clients with the characteristics of market abuse went unreported. The DFSA imposed USD 373,842; in 2021 it had temporarily prohibited the bank from handling orders of specific clients.

What organisations can take from it

A firm that outsources market abuse surveillance remains responsible for its effectiveness and must oversee it itself.

Relevance to training and awareness

Responsibility for outsourced trade surveillance

Authority / court
Dubai Financial Services Authority (DFSA)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Full cooperation with the investigation and prompt remediation of the control weaknesses.
Published
2 Nov 2023

Original amount 373,842 USD, converted at the ECB reference rate of 2 Nov 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 2 Nov 2025 · Direct link

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26 Oct 2023 a Spanish major bankAEPD: €5m fine for major bank over other customers’ transfer receipts in account access SpainData breaches and data securityanonymised €5m

A customer of the bank was able to view another customer's transfer receipt over a long period; the investigation revealed shortcomings in system design and security measures. The AEPD imposed 2,000,000 EUR (Art. 5(1)(f)), 1,500,000 EUR (Art. 25) and 1,500,000 EUR (Art. 32), 5,000,000 EUR in total, and ordered remedial measures within nine months.

What organisations can take from it

Banking systems must be designed from the outset so that customer documents cannot be displayed to other customers.

Authority / court
Agencia Española de Protección de Datos (AEPD)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 5 Abs. 1 lit. f, 25, 32 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Published
18 Apr 2024

Checked against the official source on 28 Sep 2026 · Company name anonymised since 26 Oct 2025 · Direct link

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23 Oct 2023 a major Canadian bankFINTRAC: CAD 1,329,150 penalty on major Canadian bank for 2 violations of anti-money laundering obligations CanadaSuspicious activity reportsanonymised €914,008

According to FINTRAC, the company is a bank based in Toronto, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 1,329,150 on the company on 23 October 2023. According to FINTRAC's findings, the company committed 2 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned suspicious transaction reporting and international electronic funds transfer reporting. Specifically, FINTRAC found one missed suspicious transaction report concerning a client who had been arrested and charged, and 1,003 unreported incoming international transfers in a sample of 20,000. FINTRAC stresses that the penalty was imposed for administrative violations and not for money laundering or terrorist financing offences. According to FINTRAC, the penalty has been paid in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7; PCMLTF Regulations 12(1)(c); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
7 Dec 2023

Original amount 1,329,150 CAD, converted at the ECB reference rate of 23 Oct 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 23 Oct 2025 · Direct link

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18 Oct 2023 a Polish insurerPolish insurer: 103,752 PLN – misdirected e-mail not reported after using a risk calculator PolandIncident reporting obligationsanonymised €23,362

The insurer sent a claims settlement confirmation containing name, address, vehicle and claim data by e-mail to an unauthorised person. After an assessment using an online calculator, it rated the risk as low and did not notify; the supervisory authority found that the notification obligation had been breached and treated, among other things, intent and lack of cooperation as aggravating factors.

What organisations can take from it

Risk assessment tools do not replace judgement – anyone sending out information covered by insurance secrecy should notify if in doubt.

Relevance to training and awareness

Avoiding misdirected e-mails; reporting data breaches

Authority / court
Prezes Urzędu Ochrony Danych Osobowych (UODO)
Area of law
Information security and cyber · Incident reporting obligations
Legal basis
Art. 33 Abs. 1 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
intentional
Repeat case
yes
Published
23 Nov 2023

Original amount 103,752 PLN, converted at the ECB reference rate of 18 Oct 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 18 Oct 2025 · Direct link

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16 Oct 2023 a US commercial bankFederal Reserve: USD 14.5 million against US commercial bank over prepaid accounts USACustomer due diligenceanonymised €13.7m

The Federal Reserve issued a cease and desist order and a civil money penalty of USD 14,478,676 against a US commercial bank. In 2020 the bank opened prepaid card accounts through an external programme manager without adequately verifying applicants' identities under the Customer Identification Program rule, and did not properly oversee this third-party programme. Perpetrators used the accounts with stolen identities to obtain more than USD 300 million in state unemployment benefits.

What organisations can take from it

In fintech partnerships the bank remains responsible for identity verification and fraud prevention, even when a programme manager distributes the accounts.

Relevance to training and awareness

Identity verification and third-party risk management in fintech programmes

Authority / court
Board of Governors of the Federal Reserve System
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Customer Identification Program Rule, 31 C.F.R. § 1020.220; Federal Deposit Insurance Act (12 U.S.C. § 1818(b) und (i))
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
19 Oct 2023

Original amount 14,478,676 USD, converted at the ECB reference rate of 16 Oct 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 16 Oct 2025 · Direct link

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16 Oct 2023 a Luxembourg life insurerLuxembourg life insurer: 790,000 EUR over deficiencies in anti-money laundering LuxembourgInternal controlsanonymised €790,000

An inspection in 2021 revealed that the life insurer had not carried out an overall assessment of its money laundering risks and that the guidance for employees on due diligence obligations (beneficial owners, high-risk countries, PEPs) was inadequate. The Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) imposed 790,000 EUR.

What organisations can take from it

The overall money laundering risk assessment is the basis of all due diligence obligations and must be in place before new business relationships are entered into.

Relevance to training and awareness

Customer due diligence in insurance distribution

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Loi modifiée du 12 novembre 2004 (LBC/FT), Art. 2-1, 2-2, 8-4, 8-5; Règlement CAA 20/03
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
3 Jul 2024

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11 Oct 2023 a UK minibond issuer (in administration)FCA: Public censure for minibond issuer over misleading minibond promotions United KingdomMisleading advertising and pricinganonymised Reprimand or warning

The FCA publicly censured a UK minibond issuer. The FCA found that between June 2016 and December 2018 the company promoted its minibonds to retail investors with unfair, unclear and misleading claims, for example about the supposed independence and careful selection of borrowers, although these were connected to the issuer and barely vetted. Because of insolvency and large liabilities to investors and the Financial Services Compensation Scheme (FSCS), the FCA did not impose a fine or restitution order.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
COBS 4.2.1(1)R; section 205 FSMA 2000
Action
Reprimand or warning
Status of proceedings
final
Sector
Financial services and insurance

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10 Oct 2023 a Korean life insurerKorean life insurer filed suspicious transaction and cash reports late: KoFIU fine South KoreaSuspicious activity reportsanonymised €53,166

The Korea Financial Intelligence Unit (KoFIU, Korea's financial intelligence unit) found that the insurer had reported 44 suspicious transactions from February 2021 to March 2022, which it had internally classified as reportable, not within three business days but between 2 and 324 business days late, and had filed 28 reportable cash transactions from 2018 to 2022 between 1 and 552 days late. KoFIU imposed a fine of KRW 75.9 million on 10 October 2023.

What organisations can take from it

Deadlines for suspicious transaction reports run from the internal classification; processing backlogs are themselves a breach.

Relevance to training and awareness

Timely suspicious transaction and cash reports

Authority / court
Korea Financial Intelligence Unit (KoFIU)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Art. 4 Abs. 1 und Art. 4-2 Abs. 1 Act on Reporting and Using Specified Financial Transaction Information; Art. 8-2 Durchführungsverordnung
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
12 Oct 2023

Original amount 75,900,000 KRW, converted at the ECB reference rate of 10 Oct 2023.

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10 Oct 2023 a UK business services groupICO: reprimand for business services group after a ransomware attack without multi-factor authentication United KingdomSecurity measures and risk managementanonymised Reprimand or warning

The ICO issued a reprimand to a UK business services group. According to the ICO case page, the company suffered a ransomware attack in which personal data was exfiltrated. According to the ICO's findings, there was no clear bring-your-own-device policy and no adequate account lockout policy, and multi-factor authentication had not been set up for the affected user account. As aggravating factors, the ICO noted that data had been kept for longer than necessary and that it took eleven months to notify everyone affected. The ICO found infringements of Articles 5(1)(f) and 32(1) UK GDPR. The reprimand is undated; the date follows the ICO case page.

Authority / court
Information Commissioner's Office (ICO)
Area of law
Information security and cyber · Security measures and risk management
Legal basis
Art. 5(1)(f) und 32(1) UK GDPR; Verwarnung nach Art. 58(2)(b) UK GDPR
Action
Reprimand or warning
Status of proceedings
unknown
Sector
Financial services and insurance
Sources

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5 Oct 2023 a Croatian debt collection companyCroatia: 5.47 million EUR against debt collection company after data leak CroatiaData breaches and data securityanonymised €5.47m

An anonymous tip-off accompanied by a USB stick proved that data of 181,641 debtors had leaked from the debt collection company’s records; there were no systems for detecting unusual data retrievals. In addition, the company stored health data up to and including diagnoses, data of non-debtors and call recordings without a legal basis; the Agencija za zaštitu osobnih podataka (Croatian Personal Data Protection Agency, AZOP) imposed 5.47 million EUR.

What organisations can take from it

Employees’ free-text notes can turn into impermissible health data – clear recording rules and monitoring of data retrievals are mandatory.

Relevance to training and awareness

No recording of health data in call notes

Authority / court
Agencija za zaštitu osobnih podataka (AZOP)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 5 Abs. 2, Art. 6 Abs. 1, Art. 9 Abs. 2, Art. 12, 13, 32 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
5 Oct 2023
Sources

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4 Oct 2023 a token issuer in DubaiVARA halts issuance and distribution of a token by an issuer in Dubai United Arab EmiratesOrganisational requirementsanonymised Order

The issuer had issued a token without authorisation from the Virtual Assets Regulatory Authority (VARA, Dubai's virtual assets regulator), offered it for public sale and marketed it from Dubai. VARA therefore took enforcement action and directed the company to suspend distribution immediately and to stop issuance and marketing until approval was granted; VARA announced this on 4 October 2023. After concluding its investigation, VARA regarded the matters largely as technical non-compliance and declared the case resolved on 29 December 2023 following governance commitments by the company.

What organisations can take from it

Issuing and promoting a token in a regulated market requires prior regulatory approval – even when the sale runs through a third-party platform.

Relevance to training and awareness

Approval requirements for issuing and promoting tokens

Authority / court
Virtual Assets Regulatory Authority (VARA), Dubai
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Regulation III.A.1 Virtual Assets and Related Activities Regulations 2023 (Platzierung und Vertrieb virtueller Vermögenswerte, Broker-Dealer-Lizenz); Administrative Order No. 01/2022 (Marketing, Advertising and Promotions Related to Virtual Assets)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Full cooperation and remedial measures, including improved public disclosures; VARA classed the matters largely as technical non-compliance.
Published
4 Oct 2023

Checked against the official source on 7 Oct 2026 · Company name anonymised since 4 Oct 2025 · Direct link

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3 Oct 2023 a UK credit reference agencyFCA: £11.2m fine for credit reference agency after its US parent's data breach United KingdomSecurity measures and risk managementanonymised €12.9m

The FCA fined a UK credit reference agency £11,164,400. The FCA found that the agency had outsourced the processing of UK consumer data to its US parent without adequately overseeing the security of that data, even though it knew of problems with security patching. In the 2017 cyber attack on the parent company, data of millions of people in the UK were also taken. In the FCA's view, subsequent public statements on the impact on UK consumers failed to be fair, clear and not misleading. The fine includes a 30% discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Information security and cyber · Security measures and risk management
Legal basis
FCA Principles 3, 6 und 7; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 11,164,400 GBP, converted at the ECB reference rate of 3 Oct 2023.

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3 Oct 2023 a UK company sending debt solutions marketing textsICO: GBP 50,000 fine for text marketer over debt solution marketing texts United KingdomMarketing and consentanonymised €57,620

On 3 October 2023 the ICO fined the company GBP 50,000 and served an enforcement notice on the same day. The company ran a website where consumers entered details of their debts, which were passed to providers of debt solutions. According to the ICO's findings, between 24 March and 7 September 2021 subscribers received 415,041 marketing texts from the company about debt solutions without valid consent. The ICO treated this as a breach of regulation 22 of PECR. Under the notice, early payment reduced the fine to GBP 40,000.

Authority / court
Information Commissioner's Office (ICO)
Area of law
Data protection · Marketing and consent
Legal basis
Regulation 22 PECR; section 55A DPA 1998 (Geldbuße); section 40 DPA 1998 (Enforcement Notice)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 50,000 GBP, converted at the ECB reference rate of 3 Oct 2023.

Sources

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29 Sep 2023 a US investment bankInvestment bank: 30 million USD over swap reporting failures and deficient supervision USADisclosure and reporting obligationsanonymised €28.3m

The CFTC fined the swap dealer 30 million USD. Since the reporting requirements took effect, the bank had failed to report a significant portion of its swap data accurately or on time to a swap data repository – more than 20 million swaps were back-reported – and since 2013 had given counterparties inaccurate pre-trade mid-market marks, or none at all, on more than one million occasions. According to the order, the cause was that CFTC compliance was not adequately resourced and prioritised; the fine was reduced for substantial cooperation, and the bank must implement a remediation plan and retain a consultant.

What organisations can take from it

New reporting obligations need adequate staffing and priority within compliance; otherwise errors accumulate into the millions over the years.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Sections 2(a)(13)(F), (G) und 4s(h)(1) Commodity Exchange Act; CFTC Regulations 23.431(a)(3)(i), 23.602(a), 43.3(a)(1), 45.3(b)(1), 45.4(c) und 45.6
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Substantial cooperation that materially advanced the investigation, and remediation already under way, including additional training and pre-trade booking prompts; the fine was reduced accordingly.
Published
29 Sep 2023

Original amount 30,000,000 USD, converted at the ECB reference rate of 29 Sep 2023.

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29 Sep 2023 the US subsidiary bank of a foreign bankFinCEN: USD 15 million against a foreign bank's US subsidiary over monitoring backlogs USASuspicious activity reportsanonymised €14.2m

FinCEN imposed a civil money penalty of allegedly USD 15 million on the US subsidiary bank of a foreign bank. Between April 2016 and March 2021 the bank did not maintain an adequate AML programme, at times built up substantial backlogs in transaction monitoring and did not report suspicious transactions accurately and on time.

What organisations can take from it

Growing alert backlogs in transaction monitoring are a warning sign to which management and the board must respond with additional resources.

Relevance to training and awareness

Backlogs in transaction monitoring and timely suspicious activity reporting

Authority / court
Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
31 U.S.C. § 5318(h), § 5318(g); 31 C.F.R. §§ 1020.210, 1020.320
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
29 Sep 2023

Original amount 15,000,000 USD, converted at the ECB reference rate of 29 Sep 2023.

Sources

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29 Sep 2023 a UK derivatives brokerFCA: £6.47 million against UK derivatives broker over outdated AML controls United KingdomInternal controlsanonymised €7.48m

The UK Financial Conduct Authority (FCA) imposed £6,470,600 (after a 30% discount) because, between September 2014 and October 2016, the derivatives broker had only a rudimentary customer risk assessment, no firm-wide money laundering risk assessment and no adequate ongoing monitoring; its policies referred to outdated legislation. The FCA had already raised concerns in 2014.

What organisations can take from it

Policies that refer to repealed legislation are a sure sign of a dead AML programme.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
FCA Principle 3; SYSC
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
50 to 249
Mitigating circumstances
30% settlement discount
Published
2 Oct 2023

Original amount 6,470,600 GBP, converted at the ECB reference rate of 29 Sep 2023.

Sources

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28 Sep 2023 a German payment institutionBaFin fines payment institution €150,000 over identification and monitoring failures GermanyCustomer due diligenceanonymised €150,000

BaFin (German Federal Financial Supervisory Authority) imposed a fine of 150,000 EUR on a German payment institution because its supervisory and control measures were inadequate. Obligations to continuously monitor business relationships, to update customer data and to identify contracting parties were not met. The fine is final.

What organisations can take from it

Payment institutions, too, must back identification and ongoing customer monitoring with effective controls, or the company is liable for the supervisory gap.

Relevance to training and awareness

Identifying contracting parties and keeping customer data up to date

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 130 Abs. 1 OWiG i. V. m. bußgeldbewehrten Pflichten des GwG (Aktualisierung von Kundendaten, Identifizierung der Vertragspartner)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Liability of senior managers
The fine is based on a breach of the duty of supervision under § 130 OWiG (German Administrative Offences Act).
Published
28 Sep 2023

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27 Sep 2023 a UAE payments fintechADGM: 486,000 USD fine for a payments fintech over AML failings and insurance sales United Arab EmiratesCustomer due diligenceanonymised €461,276

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the provider of prepaid cards and money transfers 486,000 USD. Between March 2021 and June 2022 its anti-money laundering policies, risk assessments, customer due diligence (for example on expected payment volumes and residential addresses) and monitoring of suspicious transactions were inadequate, with the risk assessment and due diligence failings affecting all 16,210 customers, and semi-annual reports of the money laundering reporting officer (MLRO) to the regulator were missing; in addition, from May 2021 to November 2022 the firm enrolled 1,956 customers in a group personal accident insurance scheme without the required permission. The regulator identified no specific instances of money laundering; without the 20% discount for early settlement the fine would have been 607,500 USD.

What organisations can take from it

When moving from a regulatory testing environment to full operation, AML controls and the scope of permissions must keep pace with the product range.

Relevance to training and awareness

Anti-money laundering controls as a fintech grows

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Sections 17(1) und 232 FSMR 2015; AML Rules 4.1.1(1), 4.1.1(2)(a) und (d), 4.1.1(4), 6.1.1, 6.2.1(b)(i), 7.1.1(3)(b) und (e), 8.3.1(1)(c), 8.3.2(2), 12.4.3, 14.2.1
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
No previous AML breaches, cooperation throughout including an independent third-party report, completed remediation (subject to verification by the regulator); 20% discount for early settlement.

Original amount 486,000 USD, converted at the ECB reference rate of 27 Sep 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 27 Sep 2025 · Direct link

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25 Sep 2023 a US subsidiary of a German asset managerUS asset manager: 19 million USD for misleading ESG statements USAMisleading environmental and sustainability claimsanonymised €17.9m

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

What organisations can take from it

ESG marketing statements must be backed by processes that are actually practised and documented; otherwise they become a regulatory risk.

Relevance to training and awareness

Truthful sustainability communication in sales and marketing

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
Sections 206(2), 206(4) Investment Advisers Act; Rules 206(4)-7 und 206(4)-8
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
25 Sep 2023

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

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21 Sep 2023 a New York bankOFAC: USD 31,867.90 settlement with New York bank over an account for account holders in Iran USABreaches of sanctions and embargoesanonymised €29,965

A New York-based bank is paying USD 31,867.90 under a settlement with OFAC for 30 apparent violations of the Iran sanctions. According to OFAC's findings, the bank maintained a certificate of deposit account for two individuals resident in Iran for around 26 years and processed 30 transactions totalling USD 91,051.13 through it between June 2017 and March 2021, although it knew their Iranian address. According to OFAC, a screening alert in 2016 was wrongly cleared as a permissible personal remittance. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed; the base penalty was USD 45,526. Summarised in our own words.

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
Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204 (30 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
21 Sep 2023

Original amount 31,867.9 USD, converted at the ECB reference rate of 21 Sep 2023.

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15 Sep 2023 an international bankFinCEN: USD 15 million against an international bank over correspondent banking and SARs USACustomer due diligenceanonymised €14.1m

FinCEN imposed a civil money penalty of allegedly USD 15 million on an international bank. Between October 2015 and May 2022 the bank failed to report suspicious transactions, did not maintain an adequate due diligence programme for correspondent accounts of foreign financial institutions and, from March 2021, had no effective AML programme. The bank, which is being wound up, must also surrender its licence.

What organisations can take from it

Correspondent relationships with foreign institutions in high-risk regions require dedicated due diligence that is actually applied, and ongoing monitoring.

Relevance to training and awareness

Due diligence in correspondent banking relationships in high-risk regions

Authority / court
Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
31 U.S.C. § 5318(g), (h), (i); 31 C.F.R. §§ 1020.320, 1010.610, 1020.210
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
15 Sep 2023

Original amount 15,000,000 USD, converted at the ECB reference rate of 15 Sep 2023.

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15 Sep 2023 a UK wholesale brokerFCA restricts wholesale broker over doubts on client money and financial crime United KingdomOrganisational requirementsanonymised Order

The FCA barred the wholesale broker with immediate effect from carrying on essentially all regulated activities; it could mainly still close out existing positions and continue to hold existing client money and assets. By its own admission the firm had lost confidence in its books and records and could not show that the client money and assets it held were complete; the FCA also saw a risk that the business might have been used for financial crime.

What organisations can take from it

Client money and custody assets require reconciled books at all times – a firm that cannot show they are complete will be stopped.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
s. 55L(3)(a) FSMA 2000; Threshold Conditions nach Schedule 6 FSMA (paras. 2C und 2E)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Sources

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6 Sep 2023 a Finnish insurerFinnish insurer: public warning over delayed workers' compensation claims FinlandOrganisational requirementsanonymised Reprimand or warning

The Finanssivalvonta (FIN-FSA, Finnish Financial Supervisory Authority) issued a public warning to the insurer. Between 2019 and 2022 the company had missed, over long periods and on a large scale, the deadlines of the Työtapaturma- ja ammattitautilaki (Finnish Workers' Compensation Act) – for starting claims investigations, for issuing decisions and for forwarding appeal documents – and lacked adequate internal control and reliable system data on these deadlines. The applicable provisions did not allow a penalty payment.

What organisations can take from it

Statutory processing deadlines belong in the control system: if you cannot measure them, you cannot meet them.

Relevance to training and awareness

Managing statutory processing deadlines in claims handling

Authority / court
Finanssivalvonta (FIN-FSA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
FivaL 39 § 1 mom.; Työtapaturma- ja ammattitautilaki 119 §, 127 §, 242 § 2 und 3 mom.; Vakuutusyhtiölaki (Governance) und Del. VO (EU) 2015/35
Action
Reprimand or warning
Status of proceedings
final
Sector
Financial services and insurance
Published
7 Sep 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 6 Sep 2025 · Direct link

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4 Sep 2023 a Singapore leasing providerLeasing provider: 82,000 SGD after a ransomware attack SingaporeData breaches and data securityanonymised €56,080

In June 2022 the leasing and hire-purchase provider discovered that ransomware had encrypted seven servers and six employee computers holding data of numerous individuals (customers, guarantors and employees), including identity, income and bank details. On 4 September 2023 the Personal Data Protection Commission (PDPC, Singapore's data protection authority) found a breach of the Protection Obligation because a patch for the exploited vulnerability in its VPN device had been available for two years and nine months without being installed and administrator accounts had no multi-factor authentication, and imposed 82,000 SGD.

What organisations can take from it

Install security updates promptly and protect administrator accounts with multi-factor authentication: both are regarded as minimum standards.

Relevance to training and awareness

Patch management and multi-factor authentication for administrator accounts

Authority / court
Personal Data Protection Commission (PDPC)
Area of law
Data protection · Data breaches and data security
Legal basis
Personal Data Protection Act 2012, s 24 (Protection Obligation); s 48J PDPA ([2023] SGPDPC 9)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation, prompt remediation and voluntary acceptance of responsibility under the expedited procedure.
Published
10 Nov 2023

Original amount 82,000 SGD, converted at the ECB reference rate of 4 Sep 2023.

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31 Aug 2023 a UK payments firmOFSI: disclosure of a sanctions breach by payments firm instead of a fine – cash withdrawal from the account of a company controlled by a designated person United KingdomBreaches of sanctions and embargoesanonymised Other

HM Treasury's Office of Financial Sanctions Implementation (OFSI) published a report on 31 August 2023 on a sanctions breach by a UK payments firm but did not impose a monetary penalty. According to OFSI's findings, on 30 June 2022, one day after the designation, GBP 250 in cash was withdrawn using a debit card on a business account, although the account belonged to a company owned or controlled by a designated person. The account itself had been restricted after a screening match, but the card had not; according to OFSI, the internal policy did not provide for cards to be frozen in such cases, and no specialist team was available at the weekend, so the card was only frozen on 4 July 2022. OFSI treated this as making funds available to a company owned or controlled by a designated person. The company had reported the incident itself and changed its processes; OFSI considered publication rather than a penalty to be appropriate. Type of measure: Breach published by OFSI instead of a monetary penalty (disclosure under s. 149(3) PACA 2017). The publication does not mention any pending review. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

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, reg. 12; Veröffentlichung nach s. 149(3) Policing and Crime Act 2017
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
31 Aug 2023

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 31 Aug 2025 · Direct link

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28 Aug 2023 a Swedish branch of a Danish insurerInsurer: SEK 35m as customer documents were accessible via alterable web links SwedenData breaches and data securityanonymised €2.94m

The Integritetsskyddsmyndigheten (IMY, Swedish data protection authority) fined the insurer 35,000,000 SEK. From October 2018 to February 2021, insurance documents containing health, financial and contact data and personal identity numbers of around 650,000 customers could be reached via web addresses whose document number could be altered; the vulnerability existed at another insurer, which merged into the company in 2022. According to the company, a telephone tip-off to customer service at the end of November 2020 was not recognised as a possible incident and was not passed on internally.

What organisations can take from it

External tip-offs about data leaks must be recognised in customer service as well and passed on to IT security immediately.

Relevance to training and awareness

Recognising and escalating security tip-offs in customer service; secure access control for online documents

Authority / court
Integritetsskyddsmyndigheten (IMY)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 5 Abs. 1 lit. f und Art. 32 Abs. 1 DSGVO; Art. 58 Abs. 2 und Art. 83 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 35,000,000 SEK, converted at the ECB reference rate of 28 Aug 2023.

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28 Aug 2023 an Estonian bankEstonian bank pays 900,000 EUR over AML deficiencies in correspondent banking services EstoniaCustomer due diligenceanonymised €900,000

An on-site inspection revealed deficiencies in risk assessment and management and in the monitoring of business relationships with financial institutions to which the bank offered correspondent banking services; the bank also breached record-keeping obligations. In addition to an order to improve its control systems, the Finantsinspektsioon (Estonian Financial Supervision Authority) imposed a fine of 900,000 EUR. The authority referred to the bank’s rapid growth; the bank had cooperated.

What organisations can take from it

Correspondent banking relationships require enhanced due diligence; control functions must keep pace with business growth.

Authority / court
Finantsinspektsioon (Estnische Finanzaufsicht)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Geldwäsche- und Terrorismusfinanzierungspräventionsgesetz (RahaPTS)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Constructive cooperation with the supervisory authority, start of remediation of deficiencies
Published
28 Aug 2023

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21 Aug 2023 a Hong Kong corporate finance adviserCorporate finance adviser: HKD 20m fine and sponsor ban over due diligence failures Hong KongOrganisational requirementsanonymised €2.34m

The corporate finance adviser was publicly reprimanded, fined 20,000,000 HKD and may not act as a sponsor for listing applications on the Stock Exchange of Hong Kong for at least one year from 18 August 2023 and, beyond that, until the regulator is satisfied with its sponsor controls. Across six listing applications it filed as sponsor between 2015 and 2017, three applications each lacked adequate due diligence on material business issues, correct advice on listing eligibility or disclosure of material information in the draft prospectus, and for all six the due diligence work was not properly documented.

What organisations can take from it

A sponsor must critically examine an issuer's core risks, ensure they are disclosed and document its review in a traceable way.

Relevance to training and awareness

Due diligence duties of sponsors in initial public offerings

Authority / court
Securities and Futures Commission (SFC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
s. 194 SFO (Cap. 571); Code of Conduct GP 2, GP 7, para. 12.1 und Kapitel 17 (u. a. paras. 17.1(b), 17.2, 17.3(b), 17.4, 17.6, 17.9(a), 17.10(c)); Corporate Finance Adviser Code of Conduct paras. 1.5, 2.3, 5.1, 5.7; Practice Note 21 der Listing Rules paras. 2 und 4
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
The firm's financial position (otherwise a heavier fine), commitment to an independent review of the sponsor business, cooperation, otherwise clean disciplinary record.
Published
21 Aug 2023

Original amount 20,000,000 HKD, converted at the ECB reference rate of 21 Aug 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 21 Aug 2025 · Direct link

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17 Aug 2023 a UK subsidiary of a US investment bankOfgem: GBP 5.41m fine for investment bank over unrecorded trader chats United KingdomOrganisational requirementsanonymised €6.34m

Ofgem found that wholesale energy traders at the bank communicated about energy transactions via WhatsApp on private phones between January 2018 and March 2020 without those communications being recorded and retained. Although the firm prohibited such channels, it did not monitor compliance sufficiently; the penalty of GBP 7,730,213 was reduced by 30% on settlement to GBP 5,411,149 – the first sanction of its kind in Great Britain.

What organisations can take from it

Banning private messaging apps is not enough – without monitoring, risk assessment and consequences, the firm is liable for unrecorded trader communications.

Relevance to training and awareness

Business communication via private messaging apps (off-channel)

Missing or inadequate training played a role in the decision.

Authority / court
Office of Gas and Electricity Markets (Ofgem) für die Gas and Electricity Markets Authority
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Regulation 8 Electricity and Gas (Market Integrity and Transparency) (Enforcement etc.) Regulations 2013 (REMIT Enforcement Regulations)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
30% settlement discount; admission, full cooperation and remediation through additional training, internal action and an internal investigation.
Published
23 Aug 2023

Original amount 5,411,149 GBP, converted at the ECB reference rate of 17 Aug 2023.

Checked against the official source on 3 Oct 2026 · Company name anonymised since 17 Aug 2025 · Direct link

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15 Aug 2023 a Hong Kong branch of a Swiss private bankPrivate bank (Hong Kong): HKD 16m penalty for inadequate identity and customer checks Hong KongCustomer due diligenceanonymised €1.87m

The Hong Kong branch of a Swiss private bank must pay a pecuniary penalty of 16,000,000 HKD. Despite known red flags, from February 2016 to January 2018 it did not verify in a timely manner the identity of 147 customers transferred from another institution and of their beneficial owners; from April 2012 to October 2018 it also failed to adequately verify the beneficial owners of 33 higher-risk customers, did not terminate 23 of these relationships in time and omitted trigger-event reviews of unusually large transactions of 33 customers.

What organisations can take from it

Anyone taking over a customer book from another institution must promptly carry out its own identity verification, including beneficial owners.

Relevance to training and awareness

Identifying beneficial owners and handling transferred customer books

Authority / court
Hong Kong Monetary Authority (HKMA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
s. 21(2)(c) AMLO (Cap. 615); Schedule 2 ss. 3(1), 3(3), 3(4)(b), 5(1)(a), 19(3) AMLO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Remedial and enhancement measures, no previous disciplinary record under the AMLO, cooperation with the regulator.
Published
15 Aug 2023

Original amount 16,000,000 HKD, converted at the ECB reference rate of 15 Aug 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 15 Aug 2025 · Direct link

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2 Aug 2023 a UK home appliance cover providerICO: GBP 200,000 fine for appliance cover provider over marketing calls about appliance warranties United KingdomMarketing and consentanonymised €232,455

On 2 August 2023 the ICO fined a UK provider of home appliance cover GBP 200,000 and served an enforcement notice on the same day. According to the ICO, the company came to its attention during an investigation into marketing calls to elderly and vulnerable people about maintenance and warranty cover for household appliances. According to the ICO's findings, in 2021 the company made 511,499 unsolicited marketing calls to numbers registered with the TPS, resulting in nine complaints. The people called were also not given the caller information required by law. The ICO treated this as a breach of regulations 21 and 24 of PECR. Under the notice, early payment reduced the fine to GBP 160,000. The ICO published the case on 21 September 2023.

Authority / court
Information Commissioner's Office (ICO)
Area of law
Data protection · Marketing and consent
Legal basis
Regulation 21 und 24 PECR; section 55A DPA 1998 (Geldbuße); section 40 DPA 1998 (Enforcement Notice)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 200,000 GBP, converted at the ECB reference rate of 2 Aug 2023.

Sources

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26 Jul 2023 a German payment service providerBaFin bars payment provider from high-risk merchant transactions and new clients GermanyCustomer due diligenceanonymised Order

On 26 July 2023 BaFin (German Federal Financial Supervisory Authority) prohibited a German payment service provider from processing transactions for certain business customers in a high-risk portfolio and ordered a ban on new customers in that area. A special audit had found serious deficiencies in enhanced due diligence, in particular in assessing online merchants' business models during onboarding and in their ongoing monitoring. The measure has been final since 29 August 2023.

What organisations can take from it

Onboarding high-risk merchants without applying enhanced due diligence can lead the supervisor to ban transactions and new business.

Relevance to training and awareness

Risk-based vetting and monitoring of merchants in the acquiring business

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 51 Abs. 2 S. 1 und 2 GwG; Veröffentlichung nach § 57 Abs. 1 GwG
Action
Order
Status of proceedings
final
Sector
Financial services and insurance
Published
7 Sep 2023

Checked against the official source on 2 Oct 2026 · Company name anonymised since 26 Jul 2025 · Direct link

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25 Jul 2023 an Italian insurerIVASS fines insurer €1.8m over financial risk management failings ItalyOrganisational requirementsanonymised €1.8m

IVASS (Italian insurance supervisor) imposed a fine of 1,800,000 EUR on the insurer under Art. 310(1) of the Private Insurance Code (CAP). It found shortcomings in the governance and management of financial risks and in protecting policyholders' rights for investments made through multi-asset funds, for example in the distribution of dividends, the oversight of derivatives trading and valuation controls, as well as weaknesses in the risk appetite framework and a lack of worst-case stress tests. According to IVASS, the measures in the remediation plan submitted by the company have been completed.

What organisations can take from it

Anyone investing customers' money through complex funds and derivatives needs robust valuation controls and stress tests that also cover extreme scenarios.

Relevance to training and awareness

Investment risks and policyholder protection

Authority / court
IVASS (Istituto per la Vigilanza sulle Assicurazioni)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 30-bis, 30-ter, 37-ter, 183 und 310 Abs. 1 D.Lgs. 209/2005 (CAP); IVASS-Verordnungen 24/2016, 32/2016 und 38/2018
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
31 Aug 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 25 Jul 2025 · Direct link

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24 Jul 2023 a Swiss major bankHedge fund collapse: FINMA finds serious risk management failings at major bank SwitzerlandOrganisational requirementsanonymised Order

The bank held a position of 24 billion USD vis-à-vis a hedge fund, responded inadequately to limit breaches and paid out a further 2.4 billion USD shortly before the collapse. FINMA found serious and systematic breaches of organisational requirements and ordered the bank's legal successor to introduce group-wide position limits and risk-based remuneration.

What organisations can take from it

Escalate concentration risks and limit breaches on a mandatory basis – remuneration must not ignore the risks taken.

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Bankengesetz (Organisations- und Risikomanagementpflichten)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not reported here.
Sources

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21 Jul 2023 two Swiss major banks (acquiring and acquired bank)Federal Reserve: USD 268.5 million against Swiss major banks for risk failures USAOrganisational requirementsanonymised €241.4m

The Federal Reserve issued a cease and desist order and a civil money penalty of USD 268,494,109.20 against an acquired Swiss major bank and the acquiring Swiss banking group as successor to the acquired bank's group parent. The grounds were unsafe or unsound counterparty credit risk management practices towards a family office and longstanding weaknesses in US risk management, including liquidity, model and third-party risk and data quality.

What organisations can take from it

Warning signs regarding major clients must be escalated by the independent risk function and enforced through limits or collateral.

Relevance to training and awareness

Counterparty risk and escalation of warning signs in risk management

Authority / court
Board of Governors of the Federal Reserve System
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Section 8(b) und 8(i)(2)(B) Federal Deposit Insurance Act (12 U.S.C. § 1818(b) und (i)(2)(B)); 12 C.F.R. §§ 252.155–252.157 (Regulation YY)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
24 Jul 2023

Original amount 268,494,109.2 USD, converted at the ECB reference rate of 21 Jul 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 21 Jul 2025 · Direct link

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21 Jul 2023 two UK entities of a Swiss major bankPRA: £87m fine on two UK entities of a Swiss major bank after a client default United KingdomOrganisational requirementsanonymised €100.4m

The PRA fined two UK entities of the bank a combined 87,082,000 GBP (19,162,000 GBP and 67,920,000 GBP respectively), the PRA's highest penalty to that date. Between January 2020 and March 2021 both firms failed to manage the risks from their exposures to a family office adequately, did not respond effectively to limit breaches and did not sufficiently address earlier PRA concerns; after the family office defaulted, losses of around 5.1 billion USD were booked to them. The action was part of a coordinated resolution with FINMA and the Federal Reserve Board.

What organisations can take from it

Risk limits only work if breaches are consistently escalated and reduced, including for lucrative clients and for business booked in from other group entities.

Authority / court
Prudential Regulation Authority (PRA), Bank of England
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
PRA Fundamental Rules 2, 3, 5 und 6; s. 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Early settlement with a 30% reduction (124,403,000 GBP without it).
Published
24 Jul 2023

Original amount 87,082,000 GBP, converted at the ECB reference rate of 21 Jul 2023.

Sources

Checked against the official source on 3 Oct 2026 · Company name anonymised since 21 Jul 2025 · Direct link

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18 Jul 2023 a Swiss private bank (DIFC subsidiary)DFSA: USD 3.02m on Swiss private bank subsidiary for ineffective AML controls United Arab EmiratesInternal controlsanonymised €2.69m

Between June 2018 and October 2021 the bank processed transactions for nine interconnected client accounts that showed numerous money laundering red flags, without questioning its customer information or filing suspicious transaction reports; it also classified clients as Professional Clients without evidence. The DFSA imposed USD 3,022,500: USD 975,000 disgorgement of the economic benefit and a USD 2,047,500 penalty after a 30% settlement discount (USD 3,900,000 without settlement).

What organisations can take from it

AML policies on paper are not enough – transactions must be checked continuously against the known customer profile.

Relevance to training and awareness

Recognising and reporting red flags in interconnected client accounts

Authority / court
Dubai Financial Services Authority (DFSA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 90(2) Regulatory Law 2004 (DIFC); GEN Rules 5.3.20(b), 5.3.28(b), 4.2.2; AML Rule 13.2.1 DFSA Rulebook
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Settlement (30% discount); fine reduced from USD 3,900,000 to USD 3,022,500.
Published
1 Aug 2023

Original amount 3,022,500 USD, converted at the ECB reference rate of 18 Jul 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 18 Jul 2025 · Direct link

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13 Jul 2023 a German major bank and its US entitiesFederal Reserve: USD 186 million against German major bank for delayed AML remediation USAInternal controlsanonymised €166.7m

The Federal Reserve issued a cease and desist order and a civil money penalty of USD 186,392,035 against a German major bank, its branch in New York and US entities. Of this, USD 140,192,035 relates to violations of the supervisory orders of 2015 (sanctions compliance) and 2017 (anti-money laundering), on which the bank had made insufficient progress, and USD 46,200,000 to governance and AML control failures in its former correspondent relationship with the Estonian branch of a Danish major bank, for which the US subsidiary cleared more than USD 267 billion in transactions between 2007 and 2015.

What organisations can take from it

A firm under a supervisory order must demonstrably complete its remediation – lack of progress becomes a ground for sanctions in itself.

Relevance to training and awareness

Implementing supervisory remediation requirements and correspondent banking risks

Authority / court
Board of Governors of the Federal Reserve System
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Section 8(b) und 8(i)(2) Federal Deposit Insurance Act (12 U.S.C. § 1818); Anordnungen des Board of Governors vom 04.11.2015 und 26.05.2017
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Repeat case
yes
Published
19 Jul 2023

Original amount 186,392,035 USD, converted at the ECB reference rate of 13 Jul 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 13 Jul 2025 · Direct link

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12 Jul 2023 a London brokerFCA: £2.45m fine for London broker over control failings in OTC equity trading United KingdomInternal controlsanonymised €2.87m

The FCA fined a London broker £2,452,700. The FCA found that between January 2014 and September 2015 the broker executed purported over-the-counter equity trades for clients introduced by another broker group, without adequate systems and controls against fraud and money laundering, and did not apply its own AML policies with due care. The fine includes a settlement discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
FCA Principles 2 und 3; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 2,452,700 GBP, converted at the ECB reference rate of 12 Jul 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 12 Jul 2025 · Direct link

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11 Jul 2023 a major US bankCFPB: major bank pays 140.4 million USD over repeat fees on returned payments USAConsumer protection and online retailanonymised €54.6m

The bank charged a 35 USD fee for cheques and ACH debits returned for insufficient funds and charged it again when the payee re-presented the same transaction; the CFPB found these repeat fees (September 2018 to February 2022) to be unfair. The order requires refunds of at least 80.4 million USD and a fine of 60 million USD; the parallel fine imposed by the banking supervisor OCC (60 million USD) and a second CFPB order on credit cards are not included. The authority allegedly made the findings set out here; this account is not based on a final judgment. The amount field records only the civil monetary penalty.

What organisations can take from it

Per-transaction fees must be built so that the same transaction cannot be charged more than once.

Relevance to training and awareness

Charges for returned payments and repeat fees

Authority / court
Consumer Financial Protection Bureau (CFPB)
Area of law
Consumer protection and online retail
Legal basis
Consumer Financial Protection Act of 2010, §§ 1031, 1036 (12 U.S.C. §§ 5531, 5536)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
11 Jul 2023

Original amount 60,000,000 USD, converted at the ECB reference rate of 11 Jul 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 11 Jul 2025 · Direct link

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4 Jul 2023 the Spanish branch of a foreign bankEUR 3.92m fine on a bank branch in Spain for failing to file a suspicious activity report SpainSuspicious activity reportsanonymised €3.92m

The Consejo de Ministros (Spanish Council of Ministers) imposed a fine of 3,919,300 EUR and a public reprimand on the Spanish branch of a foreign bank. It had not filed a suspicious transaction report although indications or certainty that transactions were linked to money laundering or terrorist financing had been raised internally.

What organisations can take from it

As soon as staff raise an internal money laundering suspicion, the bank must examine the matter in a documented way and report it in case of doubt; inaction counts as a very serious infringement.

Relevance to training and awareness

Duty to report suspicions after internal alerts

Authority / court
Consejo de Ministros (auf Vorschlag der Comisión de Prevención del Blanqueo de Capitales e Infracciones Monetarias)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Art. 51.1.a) i. V. m. Art. 18 und Art. 56 Ley 10/2010 de prevención del blanqueo de capitales y de la financiación del terrorismo
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
6 Mar 2025
Sources

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30 Jun 2023 an Australian insurerAustralian insurer: AUD 40m penalty for not fully passing on discounts AustraliaMisleading advertising and pricinganonymised €24.4m

The insurer, a subsidiary of an Australian insurance group, promised customers of its insurance brand loyalty and no-claim discounts on renewal but capped their effect through a pricing algorithm so that premiums did not fall below a certain threshold. After admitting around 1,098,000 false or misleading representations to more than 600,000 customers, the Court imposed AUD 40 million for the conduct from 15 October 2015; affected customers received around AUD 60 million in remediation.

What organisations can take from it

Pricing algorithms must be tested against the discount promises made to customers, otherwise every renewal becomes misleading.

Relevance to training and awareness

Honouring price and discount promises in rating and pricing systems

Authority / court
Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
s 12DB(1)(g), (i) ASIC Act 2001 (Cth); Feststellungen auch zu s 12DA(1) ASIC Act und s 912A(1)(a) Corporations Act 2001 (Cth)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Admission and jointly proposed penalty; remediation of all customers affected since March 2014.
Published
30 Jun 2023

Original amount 40,000,000 AUD, converted at the ECB reference rate of 30 Jun 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 30 Jun 2025 · Direct link

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27 Jun 2023 a UK insolvency and debt solutions firmICO: GBP 30,000 fine for debt solutions firm over debt advice marketing texts United KingdomMarketing and consentanonymised €34,888

On 27 June 2023 the ICO fined the company GBP 30,000 and served an enforcement notice on the same day. According to the ICO's findings, between 26 July 2020 and 26 July 2021 the company sent 558,354 marketing texts, 527,481 of which were delivered, without valid consent; the messages promoted debt relief plans under a trading name. The ICO treated this as a breach of regulation 22 of PECR. Under the notice, payment by 26 July 2023 reduced the fine to GBP 24,000. The ICO published the case on 28 June 2023.

Authority / court
Information Commissioner's Office (ICO)
Area of law
Data protection · Marketing and consent
Legal basis
Regulation 22 PECR; section 55A DPA 1998 (Geldbuße); section 40 DPA 1998 (Enforcement Notice)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 30,000 GBP, converted at the ECB reference rate of 27 Jun 2023.

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21 Jun 2023 three banks and a life insurer in SingaporeMAS: 3.8 million SGD against three banks and an insurer after accounting-scandal review SingaporeCustomer due diligenceanonymised €2.59m

In examinations following the irregularities in the financial statements of a German payment services provider, the Monetary Authority of Singapore (MAS, Singapore's central bank and financial regulator) found inadequate anti-money laundering controls at four institutions in dealings with persons who had transactions with, or links to, the payment services provider or its related parties: beneficial owners wrongly identified or not questioned, source of wealth not corroborated and unusually large transactions not examined. It imposed composition penalties totalling 3.8 million SGD: bank A 2.6 million, bank B 600,000, bank C 400,000 and the insurer 200,000 SGD; all institutions accepted. MAS found no wilful misconduct by staff.

What organisations can take from it

Where ownership structures are complex and large transactions look unusual, banks must ask questions and require evidence instead of accepting customer statements unchecked.

Relevance to training and awareness

Checking beneficial owners and source of wealth in complex corporate structures

Missing or inadequate training played a role in the decision.

Authority / court
Monetary Authority of Singapore (MAS)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
MAS Notice 626 (Banken) und MAS Notice 314 (Lebensversicherer); s 27B(2) Monetary Authority of Singapore Act; Composition nach s 176(1A) MAS Act 1970
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
No wilful misconduct by staff; prompt remediation through improved procedures and training to raise staff vigilance.
Published
21 Jun 2023

Original amount 3,800,000 SGD, converted at the ECB reference rate of 21 Jun 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 21 Jun 2025 · Direct link

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20 Jun 2023 a Latvian bankLatvian bank: Crimea payments via US correspondent banks USABreaches of sanctions and embargoesanonymised €3.14m

In 2015–2016, a shipping customer of the Latvian bank used online banking from an IP address in Crimea to initiate 386 payments totalling around 3.3 million USD to recipients in Crimea, which were routed through US correspondent banks. Despite a warning from a US bank, the bank relied on false customer statements and did not use the IP data available. The case was pursued by the US Treasury's Office of Foreign Assets Control (OFAC).

What organisations can take from it

Treat alerts from correspondent banks and IP location data as serious warning signs – reassuring customer explanations are no substitute for your own checks.

Relevance to training and awareness

Warning signs in payment transactions (IP geolocation, queries from correspondent banks)

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
OFAC-Sanktionen gegen die Krim-Region (E.O. 13685)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
20 Jun 2023

Original amount 3,430,900 USD, converted at the ECB reference rate of 20 Jun 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 20 Jun 2025 · Direct link

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20 Jun 2023 a Maltese investment fundMaltese investment fund fined EUR 60,141 by FIAU for inadequate risk assessment MaltaInternal controlsanonymised €60,141

Following a 2021 review, the FIAU (Financial Intelligence Analysis Unit, Malta) fined the investment fund EUR 60,141 because its business-wide money laundering risk assessment and its customer risk assessment were incomplete and the effectiveness of controls had not been assessed. The FIAU stressed that an incomplete understanding of risk can lead to ineffective controls.

What organisations can take from it

A risk assessment must not only name risks but also evaluate whether the controls against them work.

Relevance to training and awareness

Business-wide money laundering risk assessment at funds

Authority / court
Financial Intelligence Analysis Unit (FIAU)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Regulations 5(1), 5(5), 5(5)(a)(ii), 21 PMLFTR (Malta); Implementing Procedures
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The FIAU took into account the good cooperation and the fact that remedial measures had already been initiated or completed.
Published
20 Jun 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 20 Jun 2025 · Direct link

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19 Jun 2023 a French bankAMF: €1m and a warning against a French bank for failings in investment advice FranceOrganisational requirementsanonymised €1m

The AMF (Autorité des marchés financiers, French financial markets authority) Enforcement Committee found that the bank, in its investment advice business, had no effective suitability assessment procedure, no compliant client categorisation and no functioning control system, sold clients financial instruments that did not suit them, and did not inform them clearly about costs and charges. It imposed a warning and a financial penalty of 1,000,000 EUR.

What organisations can take from it

Suitability assessment, client categorisation and cost disclosure must be applied systematically in investment advice and backed by effective controls.

Relevance to training and awareness

Suitability assessment and cost transparency in investment advice

Authority / court
Autorité des marchés financiers (AMF), Commission des sanctions
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. L. 533-12, L. 533-13, L. 533-15 Code monétaire et financier; Art. 21, 22, 45, 50, 54, 55 Delegierte Verordnung (EU) 2017/565; Art. 312-41 Règlement général de l'AMF
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
20 Jun 2023

Checked against the official source on 2 Oct 2026 · Company name anonymised since 19 Jun 2025 · Direct link

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5 Jun 2023 a London capital markets brokerFCA: £17.2m fine for broker over failings in dividend arbitrage trading United KingdomInternal controlsanonymised €19.9m

On 5 June 2023 the FCA fined a London capital markets broker £17,219,300 for breaching Principles 2 and 3. The FCA found that between February 2012 and March 2015 the firm allowed an acquired equity finance business to run dividend arbitrage trading, mostly for US pension plans, without due care or effective controls; for example, there was barely any check that the tax and legal opinions meant to be a key safeguard actually existed. According to the FCA, a direct consequence was that the Danish tax authority SKAT made unjustified refunds of more than £20 million to the firm's clients, for which the firm charged £5 million in fees. The firm settled and received a 30% discount (fine before discount: £22,428,800).

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
FCA Principles 2 und 3; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 17,219,300 GBP, converted at the ECB reference rate of 5 Jun 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 5 Jun 2025 · Direct link

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31 May 2023 BlnBDI: 300,000 EUR against bank over unexplained automated credit card rejection GermanyData subject rights and transparencyanonymised €300,000

A bank (name not published) rejected an online credit card application algorithmically and, despite enquiries, refused to give the customer a comprehensible explanation of which data and criteria led to the rejection. The Berlin Commissioner for Data Protection and Freedom of Information (BlnBDI) imposed 300,000 EUR; the bank cooperated and accepted the decision.

What organisations can take from it

Companies that make automated decisions must be able to explain to data subjects in the individual case which factors were decisive.

Authority / court
Berliner Beauftragte für Datenschutz und Informationsfreiheit (BlnBDI)
Area of law
Data protection · Data subject rights and transparency
Legal basis
Art. 22 Abs. 3, Art. 5 Abs. 1 lit. a, Art. 15 Abs. 1 lit. h DSGVO
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Extensive cooperation; fine decision accepted.
Published
31 May 2023

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 31 May 2025 · Direct link

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25 May 2023 a US consumer lenderNYDFS: 4.25 million USD against US lender over shared admin accounts and default passwords USA, NYSecurity measures and risk managementanonymised €3.96m

The consumer lender allowed local administrators to share accounts and to keep using the default password issued at onboarding, had no formalised methodology for secure software development, did not carry out timely due diligence on high- and medium-risk vendors and did not adjust their risk ratings even after incidents caused by them. The New York State Department of Financial Services (NYDFS) imposed 4.25 million USD; the lender committed to extensive remedial measures.

What organisations can take from it

Tie privileged access to individual persons and reassess vendor risks after incidents – shared admin accounts make access untraceable.

Relevance to training and awareness

Handling privileged accounts and passwords; vendor management

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
Published
25 May 2023

Original amount 4,250,000 USD, converted at the ECB reference rate of 25 May 2023.

Sources

Checked against the official source on 28 Sep 2026 · Version 3 · Company name anonymised since 25 May 2025 · Direct link

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25 May 2023 a money services business based in OntarioFINTRAC: CAD 33,000 penalty on money services business for one violation of anti-money laundering obligations CanadaInternal controlsanonymised €22,604

According to FINTRAC, the company is a money services business based in Toronto, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 33,000 on the company on 25 May 2023. According to FINTRAC's findings, the company committed one violation of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violation concerned money services business registration requirements. According to FINTRAC, the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTF Regulations 11.1; Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
17 Aug 2023

Original amount 33,000 CAD, converted at the ECB reference rate of 25 May 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 25 May 2025 · Direct link

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18 May 2023 a Hong Kong securities firmSFC: HKD 6m fine for securities firm over failures as placing agent Hong KongOrganisational requirementsanonymised €708,885

The SFC publicly reprimanded the securities firm and fined it HKD 6 million over its conduct as placing agent for the then majority shareholder of another company in November and December 2019. The firm entered into trades at prices that differed from the agreed placing price, transferred the shares to the purchasers without prior payment and carried out an unverified third-party instruction to transfer part of the shares free of charge. The SFC regarded this as grossly negligent.

What organisations can take from it

An agent transferring a principal's assets must stay within the principal's instructions, secure payment before delivery and verify third-party instructions with the principal.

Relevance to training and awareness

Limits of authority and protection of the principal's assets in share placements

Authority / court
Securities and Futures Commission (SFC), Hongkong
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Section 194 Securities and Futures Ordinance (Cap. 571); Code of Conduct for Persons Licensed by or Registered with the SFC
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Repeat case
no
Mitigating circumstances
Insufficient evidence of dishonesty or recurrent misconduct; otherwise clean disciplinary record.
Published
18 May 2023

Original amount 6,000,000 HKD, converted at the ECB reference rate of 18 May 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 18 May 2025 · Direct link

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17 May 2023 a Swiss crypto foundation in bankruptcyFINMA: Swiss crypto foundation sold tokens without the required licence SwitzerlandCapital markets and financial supervisionanonymised Other

In 2021 the foundation sold its own tokens to around 500 private individuals for around EUR 3 million in an initial coin offering, although the announced learning platform with marketplace never went live; the Eidgenössische Finanzmarktaufsicht (FINMA, Swiss Financial Market Supervisory Authority) classed the token as a hybrid token with the character of a security and found that the foundation, together with its founder, had acted without authorisation as a securities firm and had also acted without authorisation as a financial intermediary, and had breached its duty to provide information. Because bankruptcy proceedings had already been opened against the foundation in March 2023 owing to over-indebtedness, FINMA only formally established the serious breach of supervisory law. The ruling was not final at the time of publication.

What organisations can take from it

Anyone selling tokens to the public must first establish whether they count as securities or means of payment and require a licence.

Relevance to training and awareness

Licensing requirements for token sales (ICOs)

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision
Legal basis
Finanzmarktrecht: unerlaubte Tätigkeit als Wertpapierhaus und als Finanzintermediärin; Auskunftspflicht gegenüber der FINMA
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
17 May 2023
Sources

Checked against the official source on 2 Oct 2026 · Company name anonymised since 17 May 2025 · Direct link

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12 May 2023 the US bank subsidiary of a British banking groupUS bank subsidiary: 45 million USD over manipulative swap trading and spoofing USAMarket abuse and insider dealinganonymised €41.3m

The CFTC fined the swap dealer 45 million USD. Between 2012 and 2015, traders deliberately traded during the pricing of interest rate swaps with bond issuers so that the relevant screen prices moved to the customers' detriment, using the counterparties' confidential information in doing so; in 2015/2016, the head of the USD swap desk placed bids and offers with a voice broker that he intended to cancel before execution (spoofing). There were also supervision failures and, from March to July 2020, a failure to record business calls made on mobile phones; the fine was reduced for substantial cooperation. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Pricing with customers must be protected from the bank's own trading, and desk heads must also be covered by trade surveillance.

Relevance to training and awareness

Spoofing and misuse of confidential customer information in trading

Missing or inadequate training played a role in the decision.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Sections 4c(a)(5)(C), 4s(h)(1)(A), (B), (D) und 6(c)(1) Commodity Exchange Act; CFTC Regulations 1.31(b)(2), 23.202(a)(1), (b)(1), 23.410(a)(3), (c)(1)(ii), 23.433, 23.602 und 180.1(a)(1)–(3)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Mitigating circumstances
Substantial cooperation and extensive remediation, including strengthened mandatory training; the CFTC recognised this with a reduced fine.
Liability of senior managers
Measures against individuals are not set out here.
Published
12 May 2023

Original amount 45,000,000 USD, converted at the ECB reference rate of 12 May 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 12 May 2025 · Direct link

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12 May 2023 a UK financial advice firmFCA: Public censure for financial adviser over pension transfer advice United KingdomConsumer protection and online retailanonymised Reprimand or warning

The FCA publicly censured a UK financial advice firm. The FCA found that between April 2015 and April 2019 the firm advised customers, including many British Steel Pension Scheme members, on transferring out of defined benefit pensions without taking reasonable care to ensure the advice was suitable. In an FCA sample review in July 2019, 5 of 17 advice files (29%) were unsuitable. A subsequent skilled person review found that 53% of the transfer advice given to British Steel Pension Scheme members and 28% of the transfer advice given to other customers was unsuitable, covering 108 files of BSPS members.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Consumer protection and online retail
Legal basis
FCA Principle 9; section 205 FSMA 2000
Action
Reprimand or warning
Status of proceedings
final
Sector
Financial services and insurance

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 12 May 2025 · Direct link

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11 May 2023 a major Canadian bank and its US broker-dealer subsidiaryMajor Canadian bank: 15 million USD over business communications via WhatsApp and text USAOrganisational requirementsanonymised €13.7m

The CFTC imposed a fine of 15 million USD, jointly and severally, on a major Canadian bank (swap dealer) and its US broker-dealer subsidiary (futures commission merchant). For years, employees up to senior levels used personal text messages and WhatsApp for business; thousands of messages that had to be retained were not preserved, and supervisors responsible for oversight also breached the firms' own policies. The firms admitted the facts and must, among other things, review their retention, training and surveillance processes.

What organisations can take from it

Using private messaging apps for business breaches record-keeping duties; policies only work if supervisors in particular comply with them and compliance is monitored.

Relevance to training and awareness

Business communications only via approved, recorded channels

Missing or inadequate training played a role in the decision.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Sections 4g, 4s(f)(1)(C), 4s(g)(1), (3) und 4s(h)(1)(B) Commodity Exchange Act; CFTC Regulations 1.31, 1.35, 23.201(a), 23.202(a)(1), (b)(1), 23.602(a) und 166.3
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
11 May 2023

Original amount 15,000,000 USD, converted at the ECB reference rate of 11 May 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 11 May 2025 · Direct link

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4 May 2023 a Croatian debt collection companyCroatia: 2.265 million EUR fine for debt collector after data exfiltration CroatiaData breaches and data securityanonymised €2.27m

The Agencija za zaštitu osobnih podataka (AZOP, Croatian Personal Data Protection Agency) fined a debt collection company 2,265,000 EUR. Prompted by an anonymous tip-off with a USB stick holding the names, dates of birth and OIB (personal identification numbers) of 77,317 debtors, it found inadequate technical and organisational security measures, unclear privacy information on the legal basis for refunds and a missing data processing agreement with a service provider.

What organisations can take from it

Anyone processing large debtor datasets must be able to detect, log and investigate data exfiltration technically.

Relevance to training and awareness

Protecting large debtor datasets and processor contracts

Authority / court
Agencija za zaštitu osobnih podataka (AZOP)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 13 Abs. 1, Art. 28 Abs. 3, Art. 32 Abs. 1 lit. b und d, Abs. 2 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Published
4 May 2023
Sources

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2 May 2023 a crypto exchange operator in DubaiVARA fines crypto exchange operator AED 10m for a market offence United Arab EmiratesCapital markets and financial supervisionanonymised €2.48m

The Virtual Assets Regulatory Authority (VARA, Dubai's virtual assets regulator) fined the operator of a crypto exchange AED 10,000,000 on 2 May 2023 for a market offence under Regulation VIII.A.3 of the Virtual Assets and Related Activities Regulations 2023. VARA had previously issued cease-and-desist orders in February and March 2023 and reprimanded the company in writing on 18 April 2023 because it was operating and promoting a crypto exchange without authorisation. The Grievance Committee upheld the measures in full; when the notice was published on 16 August 2023, the fine had not been paid.

What organisations can take from it

Ignoring a regulator's cease-and-desist orders and carrying on without a licence exposes the company to heavy fines and its leadership to personal sanctions.

Relevance to training and awareness

Licensing requirement and promotion of crypto services

Authority / court
Virtual Assets Regulatory Authority (VARA), Dubai
Area of law
Capital markets and financial supervision
Legal basis
Regulation VIII.A.3 Virtual Assets and Related Activities Regulations 2023 (Market Offence); Überprüfung durch den Grievance Committee nach Art. 22 Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
16 Aug 2023

Original amount 10,000,000 AED, converted at the ECB reference rate of 2 May 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 2 May 2025 · Direct link

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1 May 2023 a former US crypto trading platformOFAC: USD 7.59 million settlement with former crypto platform over transactions by customers in sanctioned jurisdictions USABreaches of sanctions and embargoesanonymised €6.91m

A former crypto trading platform based in Boston is paying USD 7,591,630 under a settlement with OFAC for 65,942 apparent violations of multiple sanctions programmes. According to OFAC's findings, between January 2014 and November 2019 customers apparently located in Crimea, Cuba, Iran, Sudan and Syria were able to carry out trades, deposits and withdrawals with a combined value of USD 15,335,349, although KYC information and IP addresses indicated their location. The company introduced a sanctions compliance programme only 16 months after launch and did not re-screen existing customers. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 99,237,000. Summarised in our own words.

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
E.O. 13685, Sec. 1(a)(iii) (Krim, 57.263); Cuban Assets Control Regulations, 31 C.F.R. § 515.201 (3.784); Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204 (1.466); Sudanese Sanctions Regulations (aufgehoben), 31 C.F.R. § 538.205 (3.428); Syrian Sanctions Regulations, 31 C.F.R. § 542.207 (1); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
1 May 2023

Original amount 7,591,630 USD, converted at the ECB reference rate of 28 Apr 2023.

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27 Apr 2023 a Brazilian state-owned regional bankBrazilian regional bank: BRL 2.43m for anti-money laundering failings BrazilInternal controlsanonymised €438,209

The Comitê de Decisão de Processo Administrativo Sancionador (COPAS, sanctions decision committee) of the Banco Central do Brasil (Brazilian central bank) fined a state-owned regional bank a total of BRL 2,433,463.37: BRL 268,463.37 for failing to report suspicious transactions to the financial intelligence unit Coaf and BRL 2,165,000.00 for inadequate policies, procedures and internal controls for preventing money laundering and terrorist financing. The Conselho de Recursos do Sistema Financeiro Nacional (CRSFN, financial system appeals board) upheld the bank's fines on 11 September 2024; the fine has been paid.

What organisations can take from it

Anti-money laundering controls must match the institution's size and business volume, and suspicious cases must be reported on time.

Relevance to training and awareness

Suspicious activity reporting and internal anti-money laundering controls

Authority / court
Banco Central do Brasil (Comitê de Decisão de Processo Administrativo Sancionador – COPAS)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Lei nº 9.613/1998, Art. 10, 11 und 12; Circular BCB nº 3.461/2009
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.

Original amount 2,433,463.37 BRL, converted at the ECB reference rate of 27 Apr 2023.

Checked against the official source on 14 Oct 2026 · Company name anonymised since 27 Apr 2025 · Direct link

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26 Apr 2023 a US trust and custody companyFinCEN: USD 1.5 million against trust company over unfiled suspicious activity reports USASuspicious activity reportsanonymised €1.36m

FinCEN imposed a civil money penalty of allegedly USD 1.5 million on a trust and custody company. Between February 2016 and March 2021 it built up a business line with international customers posing an elevated money laundering risk, but reviewed suspicious activity only manually and filed no suspicious activity report on hundreds of conspicuous transactions.

What organisations can take from it

Anyone expanding into a higher-risk business line must first scale suspicious activity reporting processes to the new volume and risk.

Relevance to training and awareness

Suspicious activity reporting when expanding into higher-risk business lines

Authority / court
Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
31 U.S.C. § 5318(g); 31 C.F.R. § 1020.320
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
50 to 249
Mitigating circumstances
In setting the penalty, FinCEN took the company's financial resources into account.
Published
26 Apr 2023

Original amount 1,500,000 USD, converted at the ECB reference rate of 26 Apr 2023.

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12 Apr 2023 a Hong Kong asset managerAsset manager (Hong Kong): HKD 1.4m fine for futures trading without a licence Hong KongOrganisational requirementsanonymised €163,290

The asset manager was publicly reprimanded and fined 1,400,000 HKD because between April 2014 and January 2020 it executed 4,864 futures trades for portfolios of three overseas affiliates without the required licence for dealing in futures contracts (Type 2). It had self-reported the possible breach in January 2020 and stopped futures trading afterwards.

What organisations can take from it

Intra-group trading services for overseas affiliates must also be covered by the firm's own licence.

Relevance to training and awareness

Checking licence scope: regulated activities only with the matching authorisation

Authority / court
Securities and Futures Commission (SFC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
ss. 114, 194 SFO (Cap. 571); Code of Conduct GP 2, GP 7, para. 12.1
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
No indication of intent, no client loss, self-report shortly after discovery and cessation of futures trading, cooperation, otherwise clean disciplinary record.
Published
12 Apr 2023

Original amount 1,400,000 HKD, converted at the ECB reference rate of 12 Apr 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 12 Apr 2025 · Direct link

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11 Apr 2023 two Brazilian providers of crypto investment productsTwo Brazilian crypto providers: BRL 12.99m for unregistered offering BrazilCapital markets and financial supervisionanonymised €2.36m

The board of the Comissão de Valores Mobiliários (CVM, Brazilian Securities and Exchange Commission) fined two companies marketing crypto investment products BRL 6,495,806.29 each (BRL 12,991,612.58 in total) for publicly offering securities without registration or exemption. The CVM classified the product marketed, under which the provider used client funds to buy and sell crypto-assets, as a collective investment contract (contrato de investimento coletivo) and thus as a security.

What organisations can take from it

Promising investors returns from trading crypto-assets can amount to offering a security in Brazil, which then requires CVM registration or an exemption.

Relevance to training and awareness

Public offerings of crypto-related investment products

Authority / court
Comissão de Valores Mobiliários (CVM)
Area of law
Capital markets and financial supervision
Legal basis
Lei nº 6.385/1976, Art. 19; Instrução CVM nº 400/2003, Art. 2 und 4
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
11 Apr 2023

Original amount 12,991,612.58 BRL, converted at the ECB reference rate of 11 Apr 2023.

Checked against the official source on 14 Oct 2026 · Company name anonymised since 11 Apr 2025 · Direct link

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4 Apr 2023 an Estonian bankEstonia: maximum fine for a bank over card payments reserved twice EstoniaOrganisational requirementsanonymised €32,000

The Finantsinspektsioon (Estonian Financial Supervision Authority) imposed the statutory maximum of 32,000 EUR on the bank because a technical fault on its card platform on 5 November 2022 caused the bank to reserve 7,539 payments twice without customer instructions. Affected customers could not use the double-reserved amounts from 7 to 9 November; the authority treated this as a breach of the requirements for the settlement of payments.

What organisations can take from it

Payment platforms need controls that detect erroneous duplicate reservations immediately and correct them quickly for customers.

Relevance to training and awareness

Incident and change management in payment systems

Authority / court
Finantsinspektsioon (Estnische Finanzaufsicht)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
§ 113 Abs. 2 Makseasutuste ja e-raha asutuste seadus (Gesetz über Zahlungs- und E-Geld-Institute)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
4 Apr 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 4 Apr 2025 · Direct link

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4 Apr 2023 a UK commercial bankPRA publicly censures UK bank for large exposure breaches and governance failings United KingdomOrganisational requirementsanonymised Reprimand or warning

The PRA publicly censured the bank because between December 2016 and May 2020 the bank, among other things, exceeded the 25% large exposure limit, misreported large exposures, repeatedly failed to comply with PRA requirements (OIREQs) and had no rules for retaining business messages sent via messaging services such as WhatsApp. Its business relied almost entirely on the group it belonged to and on entities introduced by that group; it was the first time the PRA found a breach of Fundamental Rule 3 (acting prudently). The PRA did not impose the fine of 8,515,000 GBP it considered appropriate because the bank was in wind-down and had hardly any resources.

What organisations can take from it

Business with one's own group needs the same independent risk assessment and large exposure management as third-party business, and business chat messages must be retained.

Relevance to training and awareness

Retention of business communications on messaging services; conflicts of interest in intra-group business

Authority / court
Prudential Regulation Authority (PRA), Bank of England
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
s. 205 FSMA 2000; PRA Fundamental Rules 3, 5 und 6; Art. 393–395 CRR; PRA Rulebook: General Organisational Requirements 2.1 und 5.1, Record Keeping 2.1, Risk Control 3.4, Related Party Transaction Risk 2.3; OIREQs nach s. 55M FSMA
Action
Reprimand or warning
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The bank was in wind-down, had very limited financial resources and settled with the PRA; no fine was therefore imposed.
Published
4 Apr 2023
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31 Mar 2023 a US payments and trading platform operatorOFAC: USD 72,230.32 settlement with platform operator over transactions for customers in Iran, Cuba and Venezuela USABreaches of sanctions and embargoesanonymised €66,419

A Californian payments and trading platform operator is paying USD 72,230.32 under a settlement with OFAC for apparent violations of the sanctions against Iran, Cuba and Venezuela. According to OFAC's findings, between March 2017 and May 2022 the company or its affiliates processed 152 transactions totalling USD 180,575.80 for customers who had themselves stated at onboarding that they were located in Iran or Cuba, and for employees of the Government of Venezuela. The information collected was not used for sanctions screening. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed; the base penalty was USD 90,288.90. Summarised in our own words.

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
Iranian Transactions and Sanctions Regulations, 31 C.F.R. §§ 560.204, 560.206, 560.215; Cuban Assets Control Regulations, 31 C.F.R. § 515.201; E.O. 13884 und Venezuela Sanctions Regulations, 31 C.F.R. § 591.201; Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
31 Mar 2023

Original amount 72,230.32 USD, converted at the ECB reference rate of 31 Mar 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 31 Mar 2025 · Direct link

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24 Mar 2023 a US bank holding companyFederal Reserve: USD 67.8 million against bank holding company over sanctions oversight USABreaches of sanctions and embargoesanonymised €63.1m

The Board of Governors of the Federal Reserve System imposed a civil money penalty of USD 67,762,500 on a US bank holding company. From 2008 to 2015 its subsidiary bank provided a trade finance platform to a foreign bank, through which around USD 532 million in transactions involving parties in sanctioned jurisdictions were processed. The Fed treated the failure of the holding company's firm-wide risk management to identify this risk as an unsafe or unsound practice; OFAC imposed a separate penalty on the bank.

What organisations can take from it

Software and platform services provided to other banks also belong in the group-wide sanctions risk assessment.

Relevance to training and awareness

Sanctions risks in software and platform services for third-party banks

Authority / court
Board of Governors of the Federal Reserve System
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Section 8(i)(2)(B) Federal Deposit Insurance Act (12 U.S.C. § 1818(i)(2)(B))
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
The bank identified the issue itself in 2015, stopped it, reported it to the authorities, remediated the violations and cooperated fully.
Published
30 Mar 2023

Original amount 67,762,500 USD, converted at the ECB reference rate of 24 Mar 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 24 Mar 2025 · Direct link

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22 Mar 2023 a major US bankOFAC: USD 30 million settlement with major US bank over a trade finance platform used for business with sanctioned countries USABreaches of sanctions and embargoesanonymised €27.8m

A major US bank is paying USD 30,000,000 under a settlement with OFAC for 124 apparent violations of three sanctions programmes. According to OFAC's findings, from 2008 to 2015 the bank and its predecessor provided a European bank with a specially customised trade finance software platform, which that bank used between December 2010 and December 2015 to process transactions worth around USD 532 million involving Iran, Sudan and Syria. Despite internal concerns, the use went unidentified and unstopped for seven years. OFAC treated the apparent violations as egregious but voluntarily self-disclosed and noted that there was no systemic breakdown of the wider compliance programme; the base penalty was USD 533,369,211. OFAC signed the settlement agreement on 22 March 2023 and published it on 30 March 2023. Summarised in our own words.

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
Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.208; Sudanese Sanctions Regulations (aufgehoben), 31 C.F.R. § 538.206; Syrian Sanctions Regulations, 31 C.F.R. § 542.210; Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
30 Mar 2023

Original amount 30,000,000 USD, converted at the ECB reference rate of 22 Mar 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 22 Mar 2025 · Direct link

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22 Mar 2023 an EU-registered credit rating agency of an international groupCredit rating agency: €1.11m ESMA fine for premature release of ratings EU levelOrganisational requirementsanonymised €1.11m

ESMA found that between June 2019 and September 2021, owing to deficient internal controls, the credit rating agency published ratings before the securities concerned had been issued and announced, removed ratings from its platforms in six cases without giving reasons, and in 2019 reported rating information to ESMA that was not up to date for 19 days. The negligent breaches of the Credit Rating Agencies Regulation were sanctioned with 825,000, 210,000 and 75,000 EUR, totalling 1,110,000 EUR, and a public notice.

What organisations can take from it

Credit rating agencies need controls ensuring that ratings are published only at the permissible time and reported correctly.

Relevance to training and awareness

Internal controls over the publication and reporting of ratings

Authority / court
Europäische Wertpapier- und Marktaufsichtsbehörde (ESMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 6 Abs. 2 i. V. m. Anhang I Abschnitt A Nr. 4, Art. 10 Abs. 1 und Art. 11a Abs. 1 VO (EG) Nr. 1060/2009 (Ratingagentur-Verordnung); Art. 24 und 36a
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Mitigating circumstances
For the first breach, voluntary measures to prevent recurrence.
Published
24 Mar 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 22 Mar 2025 · Direct link

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16 Mar 2023 a money services business based in OntarioFINTRAC: CAD 57,255 penalty on money services business for 4 violations of anti-money laundering obligations CanadaInternal controlsanonymised €39,310

According to FINTRAC, the company is a money services business based in North York, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 57,255 on the company on 16 March 2023. According to FINTRAC's findings, made during a compliance examination in 2021, the company committed 4 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned international electronic funds transfer reporting, assessing and documenting money laundering and terrorist financing risks, the prescribed review of the compliance programme and record keeping. According to FINTRAC, the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTF Regulations 28(1)(c), 30(f), 71(1)(c), 71(1)(e); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
24 May 2023

Original amount 57,255 CAD, converted at the ECB reference rate of 16 Mar 2023.

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14 Mar 2023 a Swedish major bankMajor bank: 850 million SEK – unapproved IT change led to wrong balances and blocked payments SwedenCritical infrastructureanonymised €75.3m

Finansinspektionen (Swedish Financial Supervisory Authority) issued a Swedish major bank with a remark (anmärkning) and an administrative fine of 850,000,000 SEK because on 28 April 2022 the bank made a change to a business-critical IT system – to implement new EU sanctions – without following its internal change management process: without approval by the Change Advisory Board, without a risk assessment and without a rollback plan. The resulting error stopped around 1.7 million transactions to about 1.1 million accounts, showed incorrect balances for almost 960,000 customers and prevented around 160,000 customers from making payments; because none of the bank's controls had detected that the process was bypassed, the supervisor found the internal control of this systemically important bank to be inadequate. It treated an earlier sanction from 2020 (oversight of anti-money laundering measures in subsidiary banks) as aggravating and, in the bank's favour, the fact that the breach was neither long-lasting nor systematic.

What organisations can take from it

Even urgent changes to critical IT systems prompted by regulation must go through the regular change process, and controls must detect when individuals bypass it.

Relevance to training and awareness

Change management: no change to critical IT systems without approval, risk assessment and a rollback plan

Authority / court
Finansinspektionen (FI)
Area of law
Information security and cyber · Critical infrastructure
Legal basis
6 kap. 2 § lagen (2004:297) om bank- och finansieringsrörelse (LBF) i. V. m. 2 kap. 1 § första stycket 5 FFFS 2014:1; Anmärkning nach 15 kap. 1 § LBF, Sanktionsavgift nach 15 kap. 7 § LBF
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Repeat case
yes
Mitigating circumstances
Not a long-lasting or systematic breach; the bank has taken, and announced further, measures to strengthen internal control.
Published
15 Mar 2023

Original amount 850,000,000 SEK, converted at the ECB reference rate of 14 Mar 2023.

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14 Mar 2023 an Italian bankBanca d'Italia fines Italian bank €100,000 after Bank of Italy and UIF inspections ItalySuspicious activity reportsanonymised €100,000

Following inspections by the Banca d'Italia (Bank of Italy, 4 November 2021 to 4 February 2022) and the financial intelligence unit UIF (29 November 2021 to 18 March 2022), the Banca d'Italia imposed a fine of 100,000 EUR on the bank under Art. 62 of Legislative Decree 231/2007. Shortcomings were found in customer due diligence and in active cooperation through suspicious transaction reporting (collaborazione attiva); the bank's corrective measures were taken into account.

What organisations can take from it

Inspections by the supervisor and the financial intelligence unit often run in parallel, so gaps in suspicious transaction reporting are exposed twice.

Relevance to training and awareness

Suspicious transaction reporting and customer due diligence

Authority / court
Banca d'Italia
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Art. 7, 16–19, 24, 25, 35, 36 und 62 Abs. 1 D.Lgs. 231/2007; Bestimmungen der Banca d'Italia vom 26.03.2019 und 30.07.2019
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The bank's corrective measures were taken into account.
Published
20 Apr 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 14 Mar 2025 · Direct link

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8 Mar 2023 a money services business based in OntarioFINTRAC: CAD 33,000 penalty on money services business for one violation of anti-money laundering obligations CanadaInternal controlsanonymised €22,760

According to FINTRAC, the company is a money services business based in Markham, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 33,000 on the company on 8 March 2023. According to FINTRAC's findings, made during a compliance examination in 2022, the company committed one violation of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violation concerned providing documents requested by notice. According to FINTRAC, the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
PCMLTF Regulations 63.1(2); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
24 Mar 2023

Original amount 33,000 CAD, converted at the ECB reference rate of 8 Mar 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 8 Mar 2025 · Direct link

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6 Mar 2023 an Estonian bankEstonia: bank fined after a software update disclosed bank-secrecy data EstoniaOrganisational requirementsanonymised €19,000

The Finantsinspektsioon (Estonian Financial Supervision Authority) fined the bank 19,000 EUR (maximum for legal persons: 32,000 EUR). Owing to a technical error during an update of its mobile and internet banking software, the bank had disclosed information covered by bank secrecy to third parties without a legal basis.

What organisations can take from it

Release testing of customer applications must verify that no customer data becomes visible to unauthorised persons after an update.

Relevance to training and awareness

Confidentiality of customer data in software releases

Authority / court
Finantsinspektsioon (Estnische Finanzaufsicht)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
§ 134^10 Abs. 2 Krediidiasutuste seadus (Kreditinstitutsgesetz)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
6 Mar 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 6 Mar 2025 · Direct link

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28 Feb 2023 a Swiss major bankFINMA: Swiss major bank seriously breached supervisory law over supply-chain finance funds SwitzerlandOrganisational requirementsanonymised Order

The bank had launched four supply-chain finance funds with companies of an external financing group, which were closed in March 2021 holding around USD 10 billion of client money; the Eidgenössische Finanzmarktaufsicht (FINMA, Swiss Financial Market Supervisory Authority) found that the bank had in practice left the selection and review of receivables to the partner, had warnings handled by functions that were not independent and gave FINMA partly incorrect information, and classed this as a serious breach of its duties regarding risk management and organisation. FINMA ordered that the executive board periodically review the around 500 most important business relationships for counterparty risks and that the responsibilities of the around 600 most senior managers be recorded in writing; an audit agent monitors implementation.

What organisations can take from it

Anyone distributing a partner's products under their own name must assess the risks themselves and have warnings investigated independently.

Relevance to training and awareness

Risk management for partner products; handling internal warnings

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Finanzmarktaufsichtsrecht: Pflichten zu Risikomanagement und angemessener Betriebsorganisation; Pflichten als Asset Managerin
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
FINMA opened four enforcement proceedings against former managers of the bank and requires a responsibilities document for the most senior managers in future.
Published
28 Feb 2023
Sources

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28 Feb 2023 a UAE exchange houseCBUAE revokes an exchange house's licence over AML and capital failings United Arab EmiratesOrganisational requirementsanonymised Other

The Central Bank of the UAE (CBUAE) revoked the licence of the exchange house and struck it off the register. Examinations had found that the company did not maintain the required paid-up capital and bank guarantee, was in default of equity obligations, had committed serious breaches of anti-money laundering rules and had a weak compliance framework overall. When the decision was published on 28 February 2023, the deadline for an appeal had expired without an appeal being lodged.

What organisations can take from it

Capital requirements and anti-money laundering compliance are conditions of the licence – neglecting both risks not only fines but the loss of authorisation.

Relevance to training and awareness

AML compliance and capital requirements at exchange houses

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 137 Decretal Federal Law No. (14) of 2018 Regarding the Central Bank & Organisation of Financial Institutions and Activities
Action
Other
Status of proceedings
final
Sector
Financial services and insurance
Published
28 Feb 2023

Checked against the official source on 7 Oct 2026 · Company name anonymised since 28 Feb 2025 · Direct link

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27 Feb 2023 an Irish major bankDPC: €750,000 fine against Irish major bank after unauthorised access via its banking app IrelandData breaches and data securityanonymised €750,000

The bank had notified the DPC of ten personal data breaches in which individuals were able to access other people's accounts via its banking app. The DPC found the technical and organisational measures insufficient (Art. 5(1)(f) and 32(1) GDPR), issued a reprimand, ordered remediation and imposed a fine of €750,000.

What organisations can take from it

Banking apps need robust access and account-matching controls so that customers never see other people's accounts.

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

Checked against the official source on 2 Oct 2026 · Company name anonymised since 27 Feb 2025 · Direct link

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20 Feb 2023 an Italian life insurerIVASS fines life insurer €1.55m over solvency and fee failings ItalyOrganisational requirementsanonymised €1.55m

IVASS (Italian insurance supervisor) imposed a fine of 1,550,000 EUR on the life insurer under Art. 310(1) of the Private Insurance Code (CAP). The board had underestimated the exposure of solvency to market volatility and had not adequately supervised the procedures for measuring the best estimate liability and the solvency capital requirement, which showed significant methodological weaknesses. In addition, for unit-linked life policies in one of its product ranges the company charged an annual fee for selecting and replacing funds, although this activity was carried out only for third-party funds and not for the group's own funds.

What organisations can take from it

Fees may only be charged for services actually provided; the supervisor combines such breaches with governance failings into a heavy sanction.

Relevance to training and awareness

Solvency management and fair fees in unit-linked products

Authority / court
IVASS (Istituto per la Vigilanza sulle Assicurazioni)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 30-bis, 36-bis Abs. 1 und 5, 183 Abs. 1 und 310 Abs. 1 D.Lgs. 209/2005 (CAP); IVASS-Verordnungen 18/2016, 38/2018 und 41/2018
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
31 Mar 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 20 Feb 2025 · Direct link

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17 Feb 2023 a Finnish credit reference agencyCredit agency: EUR 440,000 for ignoring an erasure order on payment default entries FinlandData subject rights and transparencyanonymised €440,000

The sanctions board of the Tietosuojavaltuutetun toimisto (Office of the Data Protection Ombudsman, Finland) fined the credit reference agency 440,000 EUR for failing to comply with an order of November 2021. Under that order it should have deleted payment default entries in the credit register that were based on final judgments in disputed civil cases; the board considered the non-compliance a deliberate decision and therefore intentional.

What organisations can take from it

A supervisory order must be implemented in full and its implementation evidenced – a narrower reading of your own does not protect against a fine.

Relevance to training and awareness

Implementing orders of the supervisory authority

Authority / court
Tietosuojavaltuutetun toimisto – seuraamuskollegio (Sanktionsgremium der Datenschutzbehörde)
Area of law
Data protection · Data subject rights and transparency
Legal basis
Art. 58 Abs. 2 lit. i, Art. 83 Abs. 6 DSGVO (Nichtbefolgung einer Anordnung nach Art. 58 Abs. 2)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
intentional
Published
2 Mar 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 17 Feb 2025 · Direct link

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16 Feb 2023 a US derivatives clearing organisationClearing organisation: 5 million USD over risk management failures USAOrganisational requirementsanonymised €4.67m

The CFTC fined a US derivatives clearing organisation 5 million USD. The clearing organisation had added a charge for liquidation costs to its margin calculation but, contrary to its own rules, did not carry it over into the calculation of its clearing fund, which as a result was underfunded by between 200 and 588 million USD at various times from October 2019 to May 2021. The CFTC treated this as a breach of the core principles for clearing organisations and expressed concern because the failures occurred after a 2019 order against the clearing organisation.

What organisations can take from it

Changes to risk methodologies must be carried through to all dependent calculations and checked.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Sections 5b(c)(2)(H) und (I) Commodity Exchange Act (7 U.S.C. § 7a-1(c)(2)(H), (I)); CFTC Regulations 39.17(a)(1) und 39.18(b)(1), (2)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
Cooperation with the investigation; the clearing organisation increased its clearing fund and began remediation, which the CFTC recognised with a reduced fine.
Published
16 Feb 2023

Original amount 5,000,000 USD, converted at the ECB reference rate of 16 Feb 2023.

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15 Feb 2023 a Canadian bank based in OntarioFINTRAC: CAD 676,500 penalty on Canadian bank for 4 violations of anti-money laundering obligations CanadaSuspicious activity reportsanonymised €471,232

According to FINTRAC, the company is a bank based in Toronto, Ontario. Canada's anti-money laundering regulator FINTRAC imposed an administrative monetary penalty of CAD 676,500 on the company on 15 February 2023. According to FINTRAC's findings, made during a compliance examination in 2022, the company committed 4 violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. As described by the regulator, the violations concerned written compliance policies and procedures, assessing and documenting money laundering and terrorist financing risks, the prescribed review of the compliance programme and suspicious transaction reporting. FINTRAC makes clear that these deficiencies are not related to money laundering or terrorist financing offences. According to FINTRAC, the penalty has been paid in full and the case is closed. Summarised in our own words; not an official version and not a reproduction of the original.

Authority / court
Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
PCMLTFA s. 7; PCMLTF Regulations 156(1)(b), 156(1)(c), 156(1)(f); Verwaltungsgeldbuße nach Teil 4.1 PCMLTFA
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
6 Mar 2023

Original amount 676,500 CAD, converted at the ECB reference rate of 15 Feb 2023.

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14 Feb 2023 a UK guarantor lenderFCA: Public censure for lender over inadequate affordability checks United KingdomConsumer protection and online retailanonymised Reprimand or warning

The FCA publicly censured a UK guarantor lender. The FCA found that between November 2018 and March 2020 the company did not adequately assess affordability for borrowers and guarantors, leading to widespread unaffordable lending. Because a fine would have jeopardised the court-approved customer redress scheme, the FCA did not impose one; it said the fine would otherwise have been £72.9 million.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Consumer protection and online retail
Legal basis
FCA Principles 2, 3 und 6; section 205 FSMA 2000
Action
Reprimand or warning
Status of proceedings
final
Sector
Financial services and insurance

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7 Feb 2023 a Hong Kong futures brokerSFC: HKD 4.8m fine for futures broker over anti-money laundering control failures Hong KongInternal controlsanonymised €571,605

The SFC publicly reprimanded the broker and fined it HKD 4.8 million because, between April 2015 and June 2018, the futures broker did not adequately assess the customer supplied trading systems used by 258 clients or manage the related money laundering risks. Unusual deposits by four clients were questioned only inadequately, and the required checks before account opening, for example on politically exposed persons and sanctions lists, were not carried out.

What organisations can take from it

Firms connecting clients through their own trading software must assess those systems for money laundering risks in advance and follow up unusual deposits consistently.

Relevance to training and awareness

Money laundering risks from customer supplied trading systems and unusual deposits

Authority / court
Securities and Futures Commission (SFC), Hongkong
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Section 194 Securities and Futures Ordinance (Cap. 571); Schedule 2 Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615); Guideline on Anti-Money Laundering and Counter-Financing of Terrorism; Code of Conduct
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Cooperation with the SFC and an otherwise clean disciplinary record.
Liability of senior managers
Measures against individuals are not set out here.
Published
7 Feb 2023

Original amount 4,800,000 HKD, converted at the ECB reference rate of 7 Feb 2023.

Checked against the official source on 14 Oct 2026 · Company name anonymised since 7 Feb 2025 · Direct link

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31 Jan 2023 an Australian major bank (Hong Kong branch)HKMA: HKD 4m fine for Australian major bank over delayed customer reviews Hong KongCustomer due diligenceanonymised €471,154

The HKMA imposed a pecuniary penalty of HKD 4 million on the Hong Kong branch of an Australian major bank because, between June 2016 and May 2017, the bank was late with 121 of 143 periodic customer reviews that fell due, including 58 high-risk customers, 27 of them by more than a year. Although the delays were known, there were no effective procedures to complete the reviews on time.

What organisations can take from it

Known backlogs in customer reviews must be cleared with resources and escalation, particularly for high-risk customers.

Relevance to training and awareness

Timely periodic review of high-risk customers

Authority / court
Hong Kong Monetary Authority (HKMA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Section 21(2)(c) Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615); Sections 5(1)(a) und 19(3) Schedule 2 AMLO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Repeat case
no
Mitigating circumstances
Deficiencies rectified, no previous disciplinary record under the AMLO and cooperation with the HKMA.
Published
31 Jan 2023

Original amount 4,000,000 HKD, converted at the ECB reference rate of 31 Jan 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 31 Jan 2025 · Direct link

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25 Jan 2023 a Maltese bankMaltese bank fined EUR 228,706 by FIAU for risk assessment and monitoring failings MaltaCustomer due diligenceanonymised €228,706

Following an offsite examination in November 2020, the FIAU (Financial Intelligence Analysis Unit, Malta) imposed a fine of EUR 228,706 and a follow-up directive on the bank. It criticised the late business-wide risk assessment, a customer risk assessment methodology that had long been inadequate, missing information on the purpose and nature of business relationships, and shortcomings in ongoing monitoring.

What organisations can take from it

A business-wide risk assessment must exist in writing – good business understanding alone does not replace it.

Relevance to training and awareness

Risk assessment and customer profile as the basis of anti-money laundering

Authority / court
Financial Intelligence Analysis Unit (FIAU)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Regulations 5(1), 5(5)(a)(ii), 7(1)(c), 7(2)(a), 7(2)(b), 21 PMLFTR (Malta); Implementing Procedures
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The FIAU acknowledged that the bank had itself identified and corrected deficiencies in the old methodology before being required to; the new methodology addresses most weaknesses.
Published
1 Feb 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 25 Jan 2025 · Direct link

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11 Jan 2023 a UK Islamic bankFCA: £4m fine for Islamic bank over anti-money laundering control failings United KingdomCustomer due diligenceanonymised €4.54m

The FCA fined a UK Islamic bank £4,023,600. The FCA found that between April 2015 and November 2017 the bank lacked adequate procedures for enhanced due diligence, in particular on the source of wealth and funds of high-risk customers, and for handling cash deposits. During that period it accepted cash deposits of over £10,000 each totalling £22.74 million. The fine includes a 30% discount.

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

Original amount 4,023,600 GBP, converted at the ECB reference rate of 11 Jan 2023.

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10 Jan 2023 a UK subsidiary of a Nigerian bankFCA: £7.7m fine for bank over repeated AML control failings United KingdomInternal controlsanonymised €8.69m

The FCA fined the UK subsidiary of a Nigerian bank £7,671,800. The FCA found that between October 2014 and July 2019 the bank failed to fix known weaknesses in its anti-money laundering controls, despite warnings from internal reviewers and an external consultant. The FCA had already fined the bank £525,000 in 2013 for similar failings and regarded the repeat as a failure of senior management. The fine includes a 30% discount.

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

Original amount 7,671,800 GBP, converted at the ECB reference rate of 10 Jan 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 10 Jan 2025 · Direct link

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4 Jan 2023 a US financial services firmNYDFS: USD 50 million penalty and compliance requirements for a financial services firm USA, New YorkInternal controlsanonymised €47.2m

The New York State Department of Financial Services imposed a penalty of allegedly USD 50 million on a US financial services firm because its BSA/AML programme and transaction monitoring were inadequate, it thereby operated in an unsafe and unsound manner, and it did not properly report a cybersecurity incident. In addition, the company committed to further investment in its compliance programme.

What organisations can take from it

If a company grows faster than its compliance, binding obligations to invest in controls may follow alongside fines.

Relevance to training and awareness

AML programme and cyber incident reporting at financial services firms

Authority / court
New York State Department of Financial Services (NYDFS)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
New York Banking Law §§ 39, 44; Financial Services Law § 408; 23 NYCRR § 200.15, § 504.3, § 500.17; 3 NYCRR § 417.2
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The NYDFS treated as mitigating the company's cooperation throughout the investigation, its willingness to enter into a memorandum of understanding (MOU) with the regulator, its engagement with the independent consultant and monitor, and substantial investment in remediating its compliance programme.
Published
4 Jan 2023

Original amount 50,000,000 USD, converted at the ECB reference rate of 4 Jan 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 4 Jan 2025 · Direct link

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2 Jan 2023 a German regional state bankRegional state bank: €6.825m ECB penalty for misreporting market risk EU levelDisclosure and reporting obligationsanonymised €6.83m

According to the ECB decision, the bank reported inaccurate risk-weighted assets and capital ratios for three quarters of 2020, because it knowingly postponed part of the parameter updates to its internal value-at-risk model for market risk and then introduced a methodological change that amounted to an unauthorised material model change. The ECB classified the breach as intentional and imposed 6,825,000 EUR; cooperation and remedial action were taken into account as mitigating.

What organisations can take from it

Material changes to internal models require prior supervisory approval.

Relevance to training and awareness

Approval requirement for model changes

Authority / court
Europäische Zentralbank (EZB), Bankenaufsicht
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 430 Abs. 1 Buchst. a VO (EU) Nr. 575/2013 (CRR); Art. 18 Abs. 1 VO (EU) Nr. 1024/2013
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Mitigating circumstances
Cooperation after the breach and remedial action.
Published
10 Feb 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 2 Jan 2025 · Direct link

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30 Dec 2022 a British fund management companyAMF: EUR 75 million sanction on UK fund manager over ineligible fund investments FranceOrganisational requirementsanonymised €75m

The Enforcement Committee of the AMF (Autorité des marchés financiers, French financial markets authority) found that the British management company had acquired, for French UCITS it managed, securities whose risks were not properly captured, which could not be reliably valued and which did not fit the investment policy; it also breached the 10% limit on debt securities of a single issuer and entered into ineligible securities financing transactions. The company received a financial penalty of EUR 75,000,000 and a reprimand. The amount covers only the sanction imposed on the company. The Conseil d'État dismissed the appeals on 13 June 2025.

What organisations can take from it

Fund managers must check and document before every acquisition whether an instrument is eligible for the UCITS, can be valued and is compatible with the investment limits.

Relevance to training and awareness

Investment limits, valuation and liquidity in UCITS funds

Authority / court
Autorité des marchés financiers (AMF), Commission des sanctions
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. L. 214-21, R. 214-9, R. 214-18, R. 214-26 Code monétaire et financier
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
3 Jan 2023

Checked against the official source on 2 Oct 2026 · Company name anonymised since 30 Dec 2024 · Direct link

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20 Dec 2022 a major US bankCFPB: 1.7 billion USD fine for a major bank over loan and account servicing USAConsumer protection and online retailanonymised €1.6bn

The CFPB found unfair practices in three business lines: in auto loans, payments were misapplied, unjustified fees and interest were charged and vehicles were wrongly repossessed; in mortgages, loan modifications were wrongly denied and fees miscalculated; in current accounts, accounts were frozen, the waiver of monthly service fees was presented misleadingly and overdraft fees were charged despite sufficient funds. The order imposes a fine of 1.7 billion USD and additionally requires the bank to pay more than 2 billion USD in redress, which the order does not state as a fixed total and which is therefore not included in the amount.

What organisations can take from it

Mass processes such as payment posting and fee calculation need ongoing controls, because small system errors across millions of accounts turn into billion-dollar harm.

Relevance to training and awareness

Fee calculation, payment posting and goodwill processes in retail banking

Authority / court
Consumer Financial Protection Bureau (CFPB)
Area of law
Consumer protection and online retail
Legal basis
Consumer Financial Protection Act of 2010, §§ 1031, 1036 (12 U.S.C. §§ 5531, 5536)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
Before the order, the bank had already provided 1.3 billion USD in remediation to more than 11 million loan accounts for the auto loan issues.
Published
20 Dec 2022

Original amount 1,700,000,000 USD, converted at the ECB reference rate of 20 Dec 2022.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 20 Dec 2024 · Direct link

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20 Dec 2022 a British bankBritish bank: 48.65 million GBP – IT migration disrupted banking services for millions of customers United KingdomCritical infrastructureanonymised €55.6m

Following the migration to a new IT platform in April 2018, customers were able to carry out banking transactions in branches, by telephone and online only to a limited extent for months; all branches and a large proportion of the 5.2 million customers were affected. The Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA) accused the bank of deficient planning, governance and management of outsourcing risk and imposed a total of 48.65 million GBP (FCA 29.75 million, PRA 18.9 million).

What organisations can take from it

Major IT migrations at providers of critical services need robust governance, testing and contingency plans – including for the critical service provider.

Authority / court
Financial Conduct Authority (FCA) und Prudential Regulation Authority (PRA)
Area of law
Information security and cyber · Critical infrastructure
Legal basis
FCA- und PRA-Anforderungen an operationelles Risikomanagement, Governance und Auslagerung
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
30% discount for settlement; 32.7 million GBP in compensation already paid to customers.

Original amount 48,650,000 GBP, converted at the ECB reference rate of 20 Dec 2022.

Sources

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 20 Dec 2024 · Direct link

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19 Dec 2022 a US futures commission merchantFutures broker: 6.5 million USD over anti-money laundering and risk limit failures USAInternal controlsanonymised €6.13m

The CFTC fined a futures commission merchant from Minnesota 6.5 million USD. From 2017 to 2020, the firm accepted net margin payments of more than 147 million USD from a customer who controlled a ranching company without adequately investigating the source of the funds or filing a suspicious activity report, and did not enforce trading limits appropriate to the customer's financial resources. The firm also failed to keep certain records of pre-trade communications and did not produce records promptly.

What organisations can take from it

Unusually large payments by a customer call for checks on the source of funds; an anti-money laundering programme must actually be applied to individual accounts.

Relevance to training and awareness

Checking the source of funds and filing suspicious activity reports

Missing or inadequate training played a role in the decision.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Section 4g(a) Commodity Exchange Act (7 U.S.C. § 6g(a)); CFTC Regulations 1.11(c)(1), (d), (e)(4), 1.31(b)(4), (d)(3)(ii), 1.73(a)(1), (2), 42.2 und 166.3
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
20 Dec 2022

Original amount 6,500,000 USD, converted at the ECB reference rate of 19 Dec 2022.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 19 Dec 2024 · Direct link

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13 Dec 2022 a German digital bankBanca d'Italia fines digital bank €160,000 over anti-money laundering control failings ItalyCustomer due diligenceanonymised €160,000

The Banca d'Italia (Bank of Italy) imposed a fine of 160,000 EUR on the digital bank under Art. 62 of Legislative Decree 231/2007. An inspection from 25 October to 17 December 2021 had found shortcomings in organisation and internal controls, particularly in customer due diligence, the use of data and suspicious transaction reporting obligations.

What organisations can take from it

Customer due diligence, the use of data and suspicious transaction reporting need firm procedures and internal controls, or the supervisor will sanction the organisational gaps themselves.

Relevance to training and awareness

Customer due diligence and suspicious transaction reporting

Authority / court
Banca d'Italia
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 7, 15–19, 24, 25, 34–36 und 62 Abs. 1 D.Lgs. 231/2007; Bestimmungen der Banca d'Italia vom 26.03.2019, 30.07.2019 und 24.03.2020
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
25 Jan 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 13 Dec 2024 · Direct link

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8 Dec 2022 a major UK bankFCA: £107.8m fine for major bank over AML control failings in business banking United KingdomInternal controlsanonymised €125m

The FCA fined a major UK bank £107,793,300. The FCA found that between December 2012 and October 2017 the bank failed to adequately manage the money laundering risks of its roughly 566,000 business banking customers, despite knowing of significant weaknesses in its control framework from the start of the period. In the FCA's view, this created an unacceptable risk that money laundering by business customers would go undetected. The fine includes a 30% discount.

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

Original amount 107,793,300 GBP, converted at the ECB reference rate of 8 Dec 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 8 Dec 2024 · Direct link

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8 Dec 2022 a UK retail bankFCA: £10m fine for bank over incorrect risk-weighted assets figure United KingdomDisclosure and reporting obligationsanonymised €11.6m

The FCA fined a UK retail bank £10,002,300. The FCA found that in its trading update of 24 October 2018 the listed bank published a risk-weighted assets figure that was too low because certain commercial loans had been weighted incorrectly, and did not disclose this. The FCA found a breach of the prohibition on publishing misleading information.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Listing Rule 1.3.3R; section 91 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 10,002,300 GBP, converted at the ECB reference rate of 8 Dec 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 8 Dec 2024 · Direct link

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8 Dec 2022 an Irish life insurer belonging to an international insurance groupCentral Bank: €3.64m fine against Irish life insurer for governance failings IrelandOrganisational requirementsanonymised €3.64m

The life insurer had sold an insurance product in Germany; around 30,000 policies referred to a guarantee from the parent company whose conditional nature was unclear in 80% of them, and for 13 years there was no effective process to identify and manage these risks. In addition, effective conflict-of-interest rules were lacking when the board considered the matter in 2018; the Central Bank issued a reprimand and imposed allegedly €3,640,000 after a 30% discount (base amount €5.2m).

What organisations can take from it

Insurers must systematically capture commitments in legacy policies and assess board conflicts of interest in a documented way, particularly in sale or group decisions.

Authority / court
Central Bank of Ireland
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
European Communities (Life Assurance) Framework Regulations 1994 (S.I. No. 360 of 1994); Corporate Governance Requirements; Delegierte Verordnung (EU) 2015/35 (Solvency II)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Settlement with a 30% discount; three breaches admitted.
Published
9 Dec 2022

Checked against the official source on 7 Oct 2026 · Version 2 · Company name anonymised since 8 Dec 2024 · Direct link

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7 Dec 2022 three London inter-dealer brokers of one groupFCA: £4.78m fines for three inter-dealer brokers over gaps in market abuse surveillance United KingdomMarket abuse and insider dealinganonymised €5.53m

The FCA fined three London inter-dealer brokers of the same group a total of £4,775,200. The FCA found that their surveillance systems for insider dealing and market manipulation did not cover all relevant asset classes; at the first broker, automated surveillance covered only equities (0.14% of trades by value) and fixed income (99.522%), but not equity derivatives, futures and options or commodities; at the second it covered only fixed income (92.46%). The gaps were not remedied throughout the relevant period. The fines include a 30% discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 16(2) MAR; FCA Principle 3; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 4,775,200 GBP, converted at the ECB reference rate of 7 Dec 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 7 Dec 2024 · Direct link

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7 Dec 2022 a Spanish bankSpanish bank: €3.145m ECB penalty for late reporting of a cyber incident EU levelIncident reporting obligationsanonymised €3.15m

The bank reported a significant cyber incident from February 2019 to the ECB not within the prescribed two hours but only 46 hours after the deadline, although it knew of the reporting obligation and the seriousness of the incident; it thereby breached an ECB decision of 23 May 2017. The ECB classified the breach as severe, imposed 3,145,000 EUR and took into account the very active cooperation and the bank's own remedial action as mitigating.

What organisations can take from it

Reporting deadlines for significant cyber incidents also apply while the crisis is being handled; notifying the supervisor belongs firmly in the incident response plan.

Relevance to training and awareness

Cyber incident reporting obligations

Authority / court
Europäische Zentralbank (EZB), Bankenaufsicht
Area of law
Information security and cyber · Incident reporting obligations
Legal basis
Art. 18 Abs. 7 VO (EU) Nr. 1024/2013; EZB-Beschluss vom 23. Mai 2017 (Meldung erheblicher Cybervorfälle)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Mitigating circumstances
Very active cooperation with the ECB, own remedial action and prompt handling of the effects of the incident.
Published
16 Dec 2022

Checked against the official source on 28 Sep 2026 · Company name anonymised since 7 Dec 2024 · Direct link

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1 Dec 2022 a German digital bankBaFin fines a digital bank €3.75m for breaches of the Money Laundering Act GermanyMoney laundering and terrorist financinganonymised €3.75m

By decision of 1 December 2022, BaFin (German Federal Financial Supervisory Authority) imposed fines totalling 3,751,500 EUR on a German digital bank for breaches of the Geldwäschegesetz (GwG, German Money Laundering Act). The notice cites § 56(1) no. 59 GwG in its 2017 version and § 56(1) no. 69 GwG in its 2020 version but does not describe the breaches in more detail. The decision has been final since 13 December 2022.

What organisations can take from it

Even where the supervisor does not describe the breaches in detail, the case shows that breaches of Money Laundering Act duties can lead to fines in the millions.

Relevance to training and awareness

Embedding Money Laundering Act obligations within the institution

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing
Legal basis
§ 56 Abs. 1 Nr. 59 GwG (Fassung vom 26.06.2017); § 56 Abs. 1 Nr. 69 GwG (Fassung vom 01.01.2020)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
21 Dec 2022

Checked against the official source on 2 Oct 2026 · Company name anonymised since 1 Dec 2024 · Direct link

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1 Dec 2022 a Welsh mortgage and financial adviser (in liquidation)FCA: £2.35m fine for financial adviser over pension transfer advice United KingdomConsumer protection and online retailanonymised €2.75m

On 1 December 2022 the FCA fined a Welsh mortgage and financial adviser (in liquidation) £2,354,331 for breaching Principles 3, 7 and 9. The FCA found that between June 2015 and December 2017 the firm advised 420 customers, almost two thirds of them British Steel Pension Scheme members, on leaving defined benefit pension schemes and recommended a transfer to about 96% of them. In the FCA's view it failed to ensure that its advice was suitable and that its communications were fair, clear and not misleading. Because the firm is in liquidation, the FCA will let valid creditors be paid first.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Consumer protection and online retail
Legal basis
FCA Principles 3, 7 und 9; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 2,354,331 GBP, converted at the ECB reference rate of 1 Dec 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 1 Dec 2024 · Direct link

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28 Nov 2022 a US crypto exchangeOFAC: USD 362,158.70 settlement with US crypto exchange over transactions by users in Iran USABreaches of sanctions and embargoesanonymised €346,133

A US crypto exchange is paying USD 362,158.70 under a settlement with OFAC and is investing a further USD 100,000 in sanctions compliance. According to OFAC's findings, between October 2015 and June 2019 the company processed 826 transactions worth around USD 1.68 million for users who appeared to be in Iran. The company checked IP addresses at onboarding but did not block them for ongoing transactions. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed; the base penalty was USD 840,288.55. Summarised in our own words.

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
Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204 (826 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
28 Nov 2022

Original amount 362,158.7 USD, converted at the ECB reference rate of 28 Nov 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 28 Nov 2024 · Direct link

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28 Nov 2022 a Maltese bankMaltese bank: EUR 82,966 and FIAU reprimand over customer due diligence failings MaltaCustomer due diligenceanonymised €82,966

Following an offsite review in 2020, the FIAU (Financial Intelligence Analysis Unit, Malta) fined the bank EUR 82,966 for shortcomings in enhanced due diligence (insufficiently verified source of wealth of one customer's politically exposed beneficial owners) and in the ongoing monitoring of transactions. The bank received a reprimand for failing, for some customers, to obtain evidence of the identity or address of beneficial owners or to verify authorised signatories at onboarding; it must also demonstrate in an action plan, among other things, the fine-tuning of its transaction monitoring.

What organisations can take from it

Transaction monitoring only helps if alerts are resolved with robust evidence of the source of funds.

Relevance to training and awareness

Source of wealth and transaction monitoring for high-risk customers

Authority / court
Financial Intelligence Analysis Unit (FIAU)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Regulations 7(1)(b), 7(2)(a), 7(3), 7(5), 8(1), 11(1)(b), 11(5), 21 PMLFTR (Malta); Implementing Procedures Part I
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The FIAU took into account the good cooperation, the remedial actions already begun and the bank's ongoing investment in its anti-money laundering framework.
Published
5 Dec 2022

Checked against the official source on 28 Sep 2026 · Company name anonymised since 28 Nov 2024 · Direct link

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22 Nov 2022 a large US asset managerAsset manager: 4 million USD for failing to follow ESG processes USAMisleading environmental and sustainability claimsanonymised €3.89m

From 2017 to 2020, the asset manager did not comply with its own ESG research policies for two ESG funds and one separately managed account strategy; questionnaires were often completed only after securities had been selected. At the same time, policies were described to third parties that were not consistently applied. The U.S. Securities and Exchange Commission (SEC) imposed 4 million USD, a censure and a cease-and-desist order.

What organisations can take from it

Companies that market products as ESG must actually and demonstrably carry out the described review processes before the investment decision.

Relevance to training and awareness

Compliance with internal ESG processes in the investment process

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
Section 206(4) Investment Advisers Act of 1940 und Rule 206(4)-7
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
22 Nov 2022

Original amount 4,000,000 USD, converted at the ECB reference rate of 22 Nov 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 22 Nov 2024 · Direct link

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21 Nov 2022 a Romanian branch of a Dutch bankBranch of a foreign bank: RON 98,076 for inadequate security in online banking RomaniaData breaches and data securityanonymised €19,848

Following a notification by the bank, the ANSPDCP (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal, Romanian data protection authority) found that unauthorised persons had obtained customers' identification, contact, account and card data as well as online banking credentials and used them to initiate payments. The authority held that the branch lacked adequate technical and organisational security measures and imposed a fine of RON 98,076.

What organisations can take from it

Online banking access must be secured so that stolen credentials alone do not allow third parties to make payments.

Relevance to training and awareness

Protecting online banking credentials

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 und 2 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
21 Nov 2022

Original amount 98,076 RON, converted at the ECB reference rate of 21 Nov 2022.

Checked against the official source on 28 Sep 2026 · Company name anonymised since 21 Nov 2024 · Direct link

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17 Nov 2022 a South African financial services providerFinancial services provider: fine for CFD trading without derivative-provider authorisation South AfricaCapital markets and financial supervisionanonymised Fine

Between 1 July 2019 and 15 December 2021, a financial services provider enabled clients to trade contracts for difference (CFDs) via a trading platform without being authorised as an over-the-counter derivative provider (ODP); the company held only a Category I FSP licence for advice and intermediary services. A fine was imposed on the company; an application for ODP authorisation was still under consideration at the time.

What organisations can take from it

A firm that itself offers derivatives such as CFDs, rather than merely arranging them, needs the specific authorisation for that activity – an intermediary licence is not enough.

Relevance to training and awareness

Scope of authorisation: arranging versus issuing derivatives

Authority / court
Financial Sector Conduct Authority (FSCA)
Area of law
Capital markets and financial supervision
Legal basis
Section 111(1) Financial Sector Regulation Act 9 of 2017 i. V. m. Section 2 ODP Regulations (Government Notice R98, Government Gazette 41433 vom 9. Februar 2018) zum Financial Markets Act 19 of 2012
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Repeat case
no
Mitigating circumstances
Full cooperation, no previous contraventions and acceptance that the authorisation requirement applied; the authority treated the breach as an oversight rather than a deliberate evasion, and the business was regularised immediately after contact.
Liability of senior managers
Measures against individuals are not set out here.
Published
17 Nov 2022

Checked against the official source on 14 Oct 2026 · Company name anonymised since 17 Nov 2024 · Direct link

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16 Nov 2022 a Romanian bankRomanian bank: RON 138,572 after 17 notified data breaches RomaniaData breaches and data securityanonymised €28,162

The investigation was triggered by 17 breach notifications from the bank, including documents sent to wrong e-mail addresses, queries of credit bureau and tax databases for an external credit broker, and indications that loans had been granted through a processor without the customers having applied. The ANSPDCP (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal, Romanian data protection authority) found breaches of the security obligations and of data protection by design and imposed three fines of RON 98,980, 14,847 and 24,745 (RON 138,572 in total) as well as two reprimands.

What organisations can take from it

Anyone giving employees access to customer data must ensure technically and organisationally that they use it only on instruction and for the intended purpose.

Relevance to training and awareness

Misdirected e-mails and staff access without instruction

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, Art. 25 Abs. 1 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
16 Nov 2022

Original amount 138,572 RON, converted at the ECB reference rate of 16 Nov 2022.

Checked against the official source on 28 Sep 2026 · Company name anonymised since 16 Nov 2024 · Direct link

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10 Nov 2022 a Singapore private bank (DIFC branch)DFSA: USD 1.12m fine on a Singapore private bank's DIFC branch for AML failings United Arab EmiratesCustomer due diligenceanonymised €1.13m

The DFSA fined the DIFC branch of a Singapore private bank USD 1,120,000 because its business and customer risk assessments, (enhanced) customer due diligence, establishment of source of funds and wealth, and suspicious activity reporting were inadequate. The branch had also arranged deals in rights under long-term insurance contracts without being authorised to do so. Because of a settlement and an Enforceable Undertaking to remedy the failings with an external compliance expert, the fine was reduced from USD 2,000,000.

What organisations can take from it

Running risk assessment, customer checks and suspicious activity reporting as a mere formality can lead to a seven-figure fine despite later remediation.

Relevance to training and awareness

Customer due diligence and source of funds in private banking

Authority / court
Dubai Financial Services Authority (DFSA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Settlement and Enforceable Undertaking (remediation, external compliance expert); fine reduced from USD 2,000,000 to USD 1,120,000.
Published
10 Nov 2022

Original amount 1,120,000 USD, converted at the ECB reference rate of 10 Nov 2022.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 10 Nov 2024 · Direct link

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10 Nov 2022 a German regional state bank (Landesbank)BaFin fines a Landesbank €498,000 for failing to report suspected insider dealing GermanyMarket abuse and insider dealinganonymised €498,000

On 10 November 2022 BaFin (German Federal Financial Supervisory Authority) imposed a fine of 498,000 EUR on a German regional state bank (Landesbank). The bank had not informed BaFin without delay of a reasonable suspicion that an order in a financial instrument constituted insider dealing; this was sanctioned as a breach of the duty of supervision. The fine is final.

What organisations can take from it

Trade surveillance does not end with detection: a reasonable suspicion of insider dealing must be reported to the supervisor without delay.

Relevance to training and awareness

Detecting suspicious orders and reporting them to BaFin

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
§ 130 Abs. 1 OWiG i. V. m. Art. 16 Abs. 2 S. 2 MAR (Verordnung (EU) Nr. 596/2014)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Liability of senior managers
The fine is based on § 130 OWiG (German Administrative Offences Act; breach of the duty of supervision within the company).
Published
23 Nov 2022

Checked against the official source on 2 Oct 2026 · Company name anonymised since 10 Nov 2024 · Direct link

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9 Nov 2022 a Hungarian bankHungarian bank: HUF 42.5m for late and missing money laundering reports HungarySuspicious activity reportsanonymised €105,321

In a targeted inspection the MNB (Magyar Nemzeti Bank, central bank of Hungary) found that the bank reported suspicious transactions to the financial intelligence unit either not at all or late, omitted follow-up reports and operated its screening system and the related internal rules inadequately. The MNB imposed fines totalling HUF 42,500,000 and ordered remediation within deadlines, an internal audit and an extraordinary report.

What organisations can take from it

Alerts from transaction monitoring must be processed on time and suspicions reported without delay.

Relevance to training and awareness

Prompt suspicious activity reporting and effective transaction monitoring

Authority / court
Magyar Nemzeti Bank (MNB)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation with the supervisor and remedial measures already taken during the inspection.
Published
9 Nov 2022

Original amount 42,500,000 HUF, converted at the ECB reference rate of 9 Nov 2022.

Checked against the official source on 28 Sep 2026 · Company name anonymised since 9 Nov 2024 · Direct link

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2 Nov 2022 a UAE investment company without a financial services permissionADGM: 2.38m USD penalty for investment firm over unauthorised loans with upfront fees United Arab EmiratesCapital markets and financial supervisionanonymised €2.4m

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) imposed a financial penalty of 2,381,798 USD on the company registered in ADGM without a financial services permission, made up of disgorgement of 1,881,798 USD, 300,000 USD for the seriousness of the contraventions and an increase of 200,000 USD for aggravating factors. From around July 2019 to June 2021 it offered loans totalling about 37 million USD without authorisation, presented itself on its website as a major asset manager, received about 2.59 million USD from four companies and individuals as 'margin deposits' or processing fees, never provided the loans and did not repay about 1.88 million USD. As an aggravating factor the regulator noted that the funds were each time withdrawn in cash or transferred abroad, in its view to avoid refunds.

What organisations can take from it

A commercial licence in a financial centre is no substitute for a financial services permission; anyone offering loans or presenting as an asset manager needs the regulator's authorisation.

Relevance to training and awareness

Licensing requirements and red flags in loan offers with upfront fees

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Capital markets and financial supervision
Legal basis
Sections 16, 20 und 232 FSMR 2015
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.

Original amount 2,381,798 USD, converted at the ECB reference rate of 2 Nov 2022.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 2 Nov 2024 · Direct link

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28 Oct 2022 a Norwegian consumer finance bankNorwegian consumer finance bank: NOK 150m for anti-money laundering control failures NorwayCustomer due diligenceanonymised €14.6m

Finanstilsynet (Norwegian Financial Supervisory Authority) fined a Norwegian consumer finance bank NOK 150,000,000 under the Anti-Money Laundering Act. An inspection in September 2021 of the bank's electronic monitoring systems and its compliance with the ICT Regulation revealed fundamental shortcomings in risk assessment, procedures, risk classification, customer due diligence and ongoing transaction monitoring; the authority also ordered extensive remediation by 1 February 2023.

What organisations can take from it

Automated transaction monitoring must be based on an up-to-date risk assessment and its rules must be reviewed regularly, otherwise it remains ineffective.

Relevance to training and awareness

Customer due diligence and transaction monitoring in banking

Authority / court
Finanstilsynet
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§§ 7, 8, 9, 12, 13, 17, 18, 24 und 25 i. V. m. §§ 49 und 50 hvitvaskingsloven; § 47 hvitvaskingsloven (Anordnung)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Liability of senior managers
Finanstilsynet attributed the negligence to the board's and management's failure to follow up the requirements of the Anti-Money Laundering Act.
Published
2 Nov 2022

Original amount 150,000,000 NOK, converted at the ECB reference rate of 28 Oct 2022.

Checked against the official source on 28 Sep 2026 · Company name anonymised since 28 Oct 2024 · Direct link

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25 Oct 2022 two Australian securities brokersTwo Australian brokers: 27.12 million AUD for systemic breaches of market rules AustraliaOrganisational requirementsanonymised €17.4m

The Federal Court of Australia, on application by the Australian Securities and Investments Commission (ASIC, Australia's corporate, markets and financial services regulator), imposed penalties of 20 million AUD on one broker and 7.12 million AUD on the other (27.12 million AUD in total) for numerous breaches of the Market Integrity Rules, including the first broker overcharging brokerage fees on 120,933 occasions (over 4.3 million AUD), non-compliance with client money reconciliation requirements, inaccurate trade confirmations and missing information in regulatory data. The court also found that both had failed to provide their financial services efficiently, honestly and fairly and that the first broker had misled customers about an execution venue; both must implement a compliance plan with independent review.

What organisations can take from it

Recurring individual breaches should be treated as a sign of systemic weakness – root-cause analysis and controls must cover the entire business.

Relevance to training and awareness

Day-to-day compliance with market integrity rules: fee charging, client money, trade confirmations

Authority / court
Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Corporations Act 2001 (Cth) ss 798H(1) (Market Integrity Rules), 912A(1)(a); ASIC Act 2001 (Cth) s 12DB (nur CommSec); Geldbußen nach s 1317G Corporations Act und s 12GBA ASIC Act
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
Early admissions and cooperation with ASIC, remediation of affected customers, contrition and investment in future compliance.
Published
26 Oct 2022

Original amount 27,120,000 AUD, converted at the ECB reference rate of 25 Oct 2022.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 25 Oct 2024 · Direct link

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24 Oct 2022 a Swiss major bankPNF: Swiss major bank pays €238m over laundering the proceeds of tax fraud FranceMoney laundering and terrorist financinganonymised €238m

The bank undertook, in a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement) with the Parquet national financier (PNF, French national financial prosecutor), to pay a public interest fine of 123,000,000 EUR and damages to the French State of 115,000,000 EUR, allegedly 238,000,000 EUR in total. The investigation opened in 2016 concerned, among other things, aggravated laundering linked to tax fraud and unlawful solicitation of clients in France (démarchage illicite); validated on 24 October 2022.

What organisations can take from it

Banks serving clients abroad must comply with local marketing rules and check the tax origin of the funds.

Relevance to training and awareness

Cross-border wealth management and clients' tax compliance

Authority / court
Parquet national financier (PNF); gerichtliche Validierung
Area of law
Money laundering and terrorist financing
Legal basis
Art. 41-1-2 Code de procédure pénale (blanchiment aggravé de fraude fiscale, démarchage illicite)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
24 Oct 2022

Checked against the official source on 14 Oct 2026 · Version 2 · Company name anonymised since 24 Oct 2024 · Direct link

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24 Oct 2022 a Spanish branch of a consumer credit institutionBanco de España: €4.5m fine on credit institution for consumer lending shortcomings SpainInformation duties in online retailanonymised €4.5m

The Banco de España (Spanish central bank and banking supervisor) imposed two fines totalling 4,500,000 EUR (3,000,000 and 1,500,000 EUR after a 40% reduction) on the Spanish branch of the consumer credit institution. The breaches concerned 2016 and 2017 and included a clause systematically inserted into loan applications by which customers also applied for a credit line that differed in repayment method and cost from the financing they had sought, shortcomings in obtaining consent to payment protection insurance, and deficiencies in interest and fee statements and in pre-contractual information and contract documents.

What organisations can take from it

Add-on products such as credit lines or payment protection insurance must not be slipped in through pre-drafted application clauses; consent and costs must be clearly recognisable.

Relevance to training and awareness

Transparency and consent in consumer credit sales

Authority / court
Banco de España
Area of law
Consumer protection and online retail · Information duties in online retail
Legal basis
Ley 10/2014 de ordenación, supervisión y solvencia de entidades de crédito; Orden 2899/2011; Circular 5/2012 del Banco de España; Ley 16/2011 de contratos de crédito al consumo; Art. 85 Ley 39/2015
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Both fines were reduced by 40% under Art. 85 Ley 39/2015 (Spanish Administrative Procedure Act).
Liability of senior managers
Measures against individuals are not reported here.
Published
18 Nov 2022

Checked against the official source on 28 Sep 2026 · Company name anonymised since 24 Oct 2024 · Direct link

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18 Oct 2022 a UK Lloyd's managing agentPRA: £9.695m fine on Lloyd's managing agent for governance and risk management failings United KingdomOrganisational requirementsanonymised €11.2m

The PRA fined the Lloyd's managing agent 9,695,000 GBP because between September 2014 and December 2019 it lacked effective risk strategies and risk management systems and failed to organise its affairs responsibly. The failings included a weak risk culture, unclear separation between the first and second lines of defence, inadequate management information and data quality, and weak underwriting controls; issues raised by the PRA were not remedied in time.

What organisations can take from it

Supervisory findings must be dealt with fully and promptly, especially when governance and controls have to keep pace with rapid growth.

Authority / court
Prudential Regulation Authority (PRA), Bank of England
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
PRA Fundamental Rules 5 und 6; s. 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Settlement at the discount stage with a 30% reduction (13,850,000 GBP without it); the PRA acknowledged the subsequent restructuring and the strengthening of the board and executive team.
Published
20 Oct 2022

Original amount 9,695,000 GBP, converted at the ECB reference rate of 18 Oct 2022.

Sources

Checked against the official source on 3 Oct 2026 · Company name anonymised since 18 Oct 2024 · Direct link

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18 Oct 2022 a US insurance services companyNYDFS: 4.5 million USD against US insurance services company – phishing of a shared mailbox without MFA USA, NYSecurity measures and risk managementanonymised €4.58m

Through a phishing attack in July 2020, attackers gained access to an email mailbox that nine employees used with the same login credentials and that was not protected by MFA; it contained six years’ worth of health data of hundreds of thousands of customers, including minors. The New York State Department of Financial Services (NYDFS) also found inadequate data disposal practices, insufficient risk assessments and incorrect compliance certifications for 2018–2021, and imposed 4.5 million USD.

What organisations can take from it

Never share login credentials and clean out old emails regularly – a shared mailbox without MFA and without retention periods turns one phishing click into a major breach.

Relevance to training and awareness

Phishing, shared login credentials and data retention in mailboxes

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
Published
18 Oct 2022

Original amount 4,500,000 USD, converted at the ECB reference rate of 18 Oct 2022.

Sources

Checked against the official source on 28 Sep 2026 · Version 3 · Company name anonymised since 18 Oct 2024 · Direct link

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18 Oct 2022 an international financial entity in Puerto RicoOFAC: Finding of Violation, no monetary penalty, against financial entity in Puerto Rico over blocked property USABreaches of sanctions and embargoesanonymised Other

OFAC issued an international financial entity in Puerto Rico with a formal Finding of Violation instead of a civil monetary penalty. According to OFAC's findings, the bank carried out three transactions totalling USD 50,271.29 involving blocked property of a person on the SDN List without the required OFAC licence, including redeeming securities and an automatic debit from a blocked account. It also failed to keep complete records of the blocked property and reported it inaccurately to OFAC in its annual reports. OFAC treated as aggravating the fact that it was known within the bank that an OFAC licence was needed. OFAC treated the bank's voluntary self-disclosure and remedial measures, among other things, as mitigating. Type of measure: Finding of Violation, no monetary penalty. The publication does not mention any pending review. Summarised in our own words.

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
Venezuela Sanctions Regulations, 31 C.F.R. § 591.202; Reporting, Procedures and Penalties Regulations, 31 C.F.R. §§ 501.601, 501.603(b)(ii); Finding of Violation nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
18 Oct 2022

Checked against the official source on 28 Sep 2026 · Version 5 · Company name anonymised since 18 Oct 2024 · Direct link

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12 Oct 2022 a UK Shariah-compliant bankFCA: £1.58m fine for Shariah-compliant bank over AML control failings United KingdomCustomer due diligenceanonymised €1.8m

By decision notice, the FCA imposed a civil penalty of £1,584,100 on a UK Shariah-compliant bank. The FCA found that between June 2014 and July 2017 the bank, many of whose customers came from higher-risk jurisdictions and some of whom were politically exposed persons, had serious weaknesses in customer due diligence and AML procedures; among other things, checks carried out by a third party were not adequately overseen. The fine includes a 30% discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Regulations 7(1)-(3), 8(1) und (3), 14(1) und (4), 20(1) MLR 2007; Regulation 42 MLR 2007
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

Original amount 1,584,100 GBP, converted at the ECB reference rate of 12 Oct 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 12 Oct 2024 · Direct link

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12 Oct 2022 a Seychelles-registered operator of a crypto trading platformCrypto platform operator: reprimand and CAD 600,000 over unregistered crypto trading Canada, OntarioOrganisational requirementsanonymised €447,928

The Seychelles-registered operator of a crypto platform offered Ontario investors securities and derivatives on crypto assets, including futures and swaps with leverage of up to 125:1, without registration and without a prospectus; 1,534 Ontario accounts were actually used. Under the approved settlement the company was reprimanded and paid an administrative penalty of CAD 600,000 and investigation costs of CAD 25,000 (CAD 625,000 in total) plus USD 514,950 in disgorgement. It also undertook not to open new Ontario accounts and to wind down leveraged products for Ontario retail clients.

What organisations can take from it

Foreign trading platforms must clarify local registration and prospectus requirements before entering a market, not only once the regulator steps in.

Relevance to training and awareness

Registration requirements for crypto trading platforms

Authority / court
Capital Markets Tribunal (Ontario) auf Antrag der Ontario Securities Commission
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Securities Act (Ontario), RSO 1990, c S.5, s. 25 (Registrierungspflicht) und s. 53 (Prospektpflicht); Anordnungen nach s. 127(1) Nr. 6, 9, 10 und s. 127.1
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
After being contacted by the Commission in 2021, the company gradually restricted access from Ontario and cooperated openly with the regulator from June 2022.
Published
12 Oct 2022

Original amount 600,000 CAD, converted at the ECB reference rate of 12 Oct 2022.

Checked against the official source on 3 Oct 2026 · Company name anonymised since 12 Oct 2024 · Direct link

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12 Oct 2022 a Hong Kong asset managerAsset manager (Hong Kong): HKD 1.75m fine over EU short-position reporting Hong KongDisclosure and reporting obligationsanonymised €229,683

The Hong Kong asset manager was publicly reprimanded and fined 1,750,000 HKD because its controls did not ensure that a net short position in the share of a London-listed oil company was reported and disclosed under the EU Short Selling Regulation; the UK Financial Conduct Authority had published a final notice on this in 2020. Before building the position in a market unfamiliar to it, the company had not sought legal advice on the reporting obligations, and it notified the Hong Kong regulator of the material breach only about two months late.

What organisations can take from it

Anyone building positions in a new market must clarify its reporting and disclosure obligations in advance and report breaches to the home regulator at once.

Relevance to training and awareness

Reporting and disclosure obligations for short positions abroad

Authority / court
Securities and Futures Commission (SFC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
s. 194 SFO (Cap. 571); Code of Conduct GP 2, GP 7, paras. 12.1, 12.5; Verordnung (EU) Nr. 236/2012
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Remedial measures to strengthen reporting controls, cooperation, otherwise clean disciplinary record.
Liability of senior managers
Measures against individuals are not set out here.
Published
12 Oct 2022

Original amount 1,750,000 HKD, converted at the ECB reference rate of 12 Oct 2022.

Checked against the official source on 14 Oct 2026 · Company name anonymised since 12 Oct 2024 · Direct link

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11 Oct 2022 a US crypto exchangeOFAC: USD 24.28 million settlement with US crypto exchange over trading by users in sanctioned regions USABreaches of sanctions and embargoesanonymised €25m

A crypto exchange based in Washington State is paying USD 24,280,829.20 under a settlement with OFAC for 116,421 apparent violations of several sanctions programmes. According to OFAC's findings, between March 2014 and December 2017 users apparently located in Crimea, Cuba, Iran, Sudan and Syria were able to carry out virtual currency transactions of around USD 263.45 million through 1,730 accounts. Although IP and address data were available, the company did not screen them for sanctioned locations until October 2017. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 485,616,584. The settlement is part of a global resolution with FinCEN. Summarised in our own words.

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
E.O. 13685, Sec. 1(a)(iii) (Krim); Cuban Assets Control Regulations, 31 C.F.R. § 515.201; Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204; Sudanese Sanctions Regulations (aufgehoben), 31 C.F.R. § 538.205; Syrian Sanctions Regulations, 31 C.F.R. § 542.207; Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
11 Oct 2022

Original amount 24,280,829.2 USD, converted at the ECB reference rate of 11 Oct 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 11 Oct 2024 · Direct link

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7 Oct 2022 a major Japanese securities firm and its financial holding companySecurities firm: partial ban after propping up prices in block offers and firewall breaches JapanMarket abuse and insider dealinganonymised Order

The securities firm was barred from new block-offer business from 7 October 2022 to 6 January 2023 and received a business improvement order; its parent, a financial holding company, was ordered to take improvement measures. For ten listed shares, the firm had supported the closing price on the block-offer execution date through limit purchases (Art. 159(3) FIEA), its trade surveillance did not act on such single-day transactions, and staff up to executive managing officers exchanged non-public information with the group bank despite clients’ express wishes.

What organisations can take from it

Information barriers between a bank and a securities firm only work if clients’ wishes are enforced technically and organisationally, including against senior management.

Relevance to training and awareness

Information barriers between bank and securities firm; price support in proprietary trading

Authority / court
Financial Services Agency (FSA, 金融庁) auf Empfehlung der Securities and Exchange Surveillance Commission (SESC, 証券取引等監視委員会)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Financial Instruments and Exchange Act (FIEA, 金融商品取引法) Art. 52 Abs. 1, Art. 51, Art. 32-2 Abs. 2; Art. 159 Abs. 3 FIEA; Art. 44-3 Abs. 1 Nr. 4 FIEA i. V. m. Art. 153 Abs. 1 Nr. 7 Cabinet Office Order on Financial Instruments Business
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
According to the findings, executive managing officers were directly involved in improperly receiving and passing on non-public information; the order required management responsibility to be clarified.
Published
7 Oct 2022

Checked against the official source on 8 Oct 2026 · Company name anonymised since 7 Oct 2024 · Direct link

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4 Oct 2022 a London brokerFCA: £531,600 fine for broker over reporting and surveillance failings United KingdomDisclosure and reporting obligationsanonymised €609,123

The FCA fined a London broker £531,600. The FCA found that between December 2014 and August 2016 the firm failed to report transactions properly and did not meet its obligations on suspicious transaction reporting and market abuse surveillance. In the FCA's view, the firm had expanded into new business areas without adequately assessing the changed risks, and its board failed in basic oversight tasks. The fine includes a 10% discount.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
SUP 17.1.4R; SUP 17.4.1 EU; SUP 15.10.2R; Art. 16(2) MAR; FCA Principle 3; section 206 FSMA 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance

Original amount 531,600 GBP, converted at the ECB reference rate of 4 Oct 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 4 Oct 2024 · Direct link

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30 Sep 2022 a US provider of electronic rewards and gift cardsOFAC: USD 116,048.60 settlement with rewards provider over rewards sent to sanctioned countries USABreaches of sanctions and embargoesanonymised €119,049

A Seattle-based provider of electronic rewards and gift cards is paying USD 116,048.60 under a settlement with OFAC. According to OFAC's findings, owing to deficient geolocation checks the company sent at least 27,720 stored value products to recipients whose IP or email addresses pointed to Cuba, Iran, Syria, North Korea and Crimea. This came to light in 2021 when a client noticed top-level domains of sanctioned countries in recipient addresses. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed and took into account cooperation and remedial measures such as geoblocking; the base penalty was USD 193,414.33. Summarised in our own words.

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
Cuban Assets Control Regulations, 31 C.F.R. § 515.201; Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204; Syrian Sanctions Regulations, 31 C.F.R. § 542.207; North Korea Sanctions Regulations, 31 C.F.R. § 510.206; E.O. 13685 (Krim); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
30 Sep 2022

Original amount 116,048.6 USD, converted at the ECB reference rate of 30 Sep 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 30 Sep 2024 · Direct link

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29 Sep 2022 a US futures exchangeUS futures exchange: 6.5 million USD – without adequate security testing USACritical infrastructureanonymised €6.7m

From 2017 to 2021, the New York futures exchange failed to comply with key system safeguards obligations: no controls testing, inadequate internal and external penetration testing, deficient technology risk assessments without involvement of the board and late notification of a security-relevant system change. In addition, there were reporting violations and a false statement to the Commodity Futures Trading Commission (CFTC); owing to cooperation, the penalty was reduced to 6.5 million USD.

What organisations can take from it

Exchanges and other market infrastructures must not only carry out security tests but also demonstrably bring their results before the 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 Designated Contract Markets
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Substantial cooperation and remediation; penalty reduced accordingly.

Original amount 6,500,000 USD, converted at the ECB reference rate of 29 Sep 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 29 Sep 2024 · Direct link

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28 Sep 2022 a US regional bankCFPB: regional bank pays 191 million USD over surprise overdraft fees USAConsumer protection and online retailanonymised €52.3m

From August 2018 to July 2021 the bank charged overdraft fees on card payments and withdrawals that were covered at authorisation and only went negative when they later settled, although it knew that authorities had already objected to such fees at other institutions. The CFPB ordered at least 141 million USD in refunds and a fine of 50 million USD (191 million USD in total); on 21 July 2025 it terminated the open-ended order after the fine and refunds had been paid. The authority allegedly made the findings set out here; this account is not based on a final judgment. The amount field records only the civil monetary penalty.

What organisations can take from it

Anyone who knows that a fee practice has been challenged at competitors should stop it at once rather than first looking for replacement revenue.

Relevance to training and awareness

Fee models and overdraft charges in account business

Authority / court
Consumer Financial Protection Bureau (CFPB)
Area of law
Consumer protection and online retail
Legal basis
Consumer Financial Protection Act of 2010, §§ 1031, 1036 (12 U.S.C. §§ 5531, 5536)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
28 Sep 2022

Original amount 50,000,000 USD, converted at the ECB reference rate of 28 Sep 2022.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 28 Sep 2024 · Direct link

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28 Sep 2022 a German major bankBaFin orders a major bank to take further AML measures and threatens penalty payments GermanyMoney laundering and terrorist financinganonymised Order

On 28 September 2022 BaFin (German Federal Financial Supervisory Authority) ordered a German major bank to take specific measures to prevent money laundering and terrorist financing, which the bank must adopt to implement BaFin's orders of 21 September 2018 and 15 February 2019. BaFin threatened penalty payments in the event of non-compliance. The decision has been final since 1 November 2022.

What organisations can take from it

The supervisor can follow up earlier AML orders with specific individual measures and threaten penalty payments to secure their implementation.

Relevance to training and awareness

Implementing supervisory AML orders

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing
Legal basis
§ 51 Abs. 2 S. 1 GwG; Veröffentlichung nach § 57 GwG
Action
Order
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Repeat case
yes
Published
4 Nov 2022

Checked against the official source on 2 Oct 2026 · Company name anonymised since 28 Sep 2024 · Direct link

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27 Sep 2022 an Irish major bankCentral Bank: record €100.52m fine against Irish major bank over tracker mortgages IrelandConsumer protection and online retailanonymised €100.5m

The bank admitted 81 breaches of consumer protection requirements affecting 15,910 tracker mortgage accounts between 2004 and 2022: unclear contract documents, interpretation to customers' detriment, missing warnings and the exclusion of more than 5,000 customers from the review; 50 properties, including 25 family homes, were lost. The Central Bank issued a reprimand and set the €143.6m fine at allegedly €100,520,000 after a 30% settlement discount, in addition to more than €186.4m already paid to customers.

What organisations can take from it

Unclear contract terms must be interpreted in customers' favour and complaints treated equally – selective redress only for those who complain is itself a breach.

Authority / court
Central Bank of Ireland
Area of law
Consumer protection and online retail
Legal basis
European Communities (Unfair Terms in Consumer Contracts) Regulations 1995; Code of Practice for Credit Institutions 2001; Consumer Protection Codes 2006 und 2012; Administrative Sanctions Procedure (Part IIIC Central Bank Act 1942)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Settlement under the administrative sanctions procedure with a 30% discount; all breaches admitted.
Published
29 Sep 2022

Checked against the official source on 7 Oct 2026 · Version 2 · Company name anonymised since 27 Sep 2024 · Direct link

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27 Sep 2022 a major German bank and its US securities subsidiaryMajor German bank: 75 million USD over business communications on private channels USAOrganisational requirementsanonymised €77.8m

The CFTC imposed a fine of 75 million USD, jointly and severally, on a major German bank and its US securities subsidiary; the order was one of a series of separate orders against eleven financial groups issued on the same day. For years, employees up to managing director level used personal text messages, WhatsApp and other unapproved channels for business, so the bank did not retain the records and, in two instances, had not collected and reviewed messages of employees relevant to earlier CFTC subpoenas. The bank admitted the facts and must, among other things, carry out a comprehensive review of its policies, training and surveillance.

What organisations can take from it

A firm that tolerates private channels cannot fully answer regulators' requests for information; communication policies must be enforced technically and through discipline.

Relevance to training and awareness

Business communications only via approved, recorded channels

Missing or inadequate training played a role in the decision.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Sections 4g, 4s(f)(1)(C), 4s(g)(1), (3) und 4s(h)(1)(B) Commodity Exchange Act; CFTC Regulations 1.31, 1.35, 23.201(a), 23.202(a)(1), (b)(1), 23.602(a) und 166.3
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
By its own account, the bank had already set up a task force of Management Board members and senior control function staff, retained a consultant to advise on improving its controls and invested in technology for compliant communications.
Published
27 Sep 2022

Original amount 75,000,000 USD, converted at the ECB reference rate of 27 Sep 2022.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 27 Sep 2024 · Direct link

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26 Sep 2022 a Swiss private bankOFAC: USD 720,258 settlement with Swiss bank over US dollar business for customers in sanctioned regions USABreaches of sanctions and embargoesanonymised €746,691

A Swiss bank is paying USD 720,258 under a settlement with OFAC for apparent violations of the Cuba, Ukraine/Crimea, Iran, Sudan and Syria sanctions. According to OFAC's findings, from April 2013 to April 2016 the bank ran US dollar accounts for 17 individual customers in those regions and processed for them 240 securities purchases worth around USD 2.05 million through US brokers and 33 payments worth around USD 1.03 million through US correspondent banks, although their home addresses were known from KYC files. OFAC treated the apparent violations as voluntarily self-disclosed and non-egregious; the base penalty was USD 1,108,090. Summarised in our own words.

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
Cuban Assets Control Regulations, 31 C.F.R. § 515.201; E.O. 13685, Sec. 1(a)(iii) (Krim); Iranian Transactions and Sanctions Regulations, 31 C.F.R. §§ 560.203, 560.204; Sudanese Sanctions Regulations, 31 C.F.R. § 538.205; Syrian Sanctions Regulations, 31 C.F.R. § 542.207; Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
26 Sep 2022

Original amount 720,258 USD, converted at the ECB reference rate of 26 Sep 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 26 Sep 2024 · Direct link

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26 Sep 2022 a Monaco-based private bankOFAC: USD 401,039 settlement with Monaco bank over US dollar business for customers in sanctioned countries USABreaches of sanctions and embargoesanonymised €415,757

A Monaco-based bank is paying USD 401,039 under a settlement with OFAC for apparent violations of the Cuba, Iran and Syria sanctions. According to OFAC's findings, from December 2011 to July 2016 the bank ran US dollar accounts for eleven individual customers resident in those countries and processed for them 410 securities purchases worth around USD 966,000 through US brokers and 16 payments worth around USD 267,000 through US correspondent banks, although their home addresses were known from KYC files. OFAC treated the apparent violations as voluntarily self-disclosed and non-egregious; the base penalty was USD 616,983. Summarised in our own words.

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
Cuban Assets Control Regulations, 31 C.F.R. § 515.201; Iranian Transactions and Sanctions Regulations, 31 C.F.R. §§ 560.203, 560.204; Syrian Sanctions Regulations, 31 C.F.R. § 542.207; Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
26 Sep 2022

Original amount 401,039 USD, converted at the ECB reference rate of 26 Sep 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 26 Sep 2024 · Direct link

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23 Sep 2022 a Hong Kong branch of a Taiwanese bankBank (Hong Kong): HKD 11m penalty for customer due diligence failings Hong KongCustomer due diligenceanonymised €1.44m

The Hong Kong branch of a Taiwanese bank must pay a pecuniary penalty of 11,000,000 HKD. Between April 2012 and February 2016 it did not effectively review the customer data of 249 customers – trigger-event reviews mostly consisted of a telephone check of a few details – and took no enhanced due diligence measures for 17 high-risk customers, such as senior management approval or establishing the source of wealth and funds. Effective procedures and safeguards against these contraventions were also lacking.

What organisations can take from it

Periodic and trigger-event customer reviews need substance; a brief telephone check does not replace enhanced due diligence for high-risk customers.

Relevance to training and awareness

Customer due diligence and enhanced due diligence for high-risk customers

Authority / court
Hong Kong Monetary Authority (HKMA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
s. 21(2)(c) AMLO (Cap. 615); Schedule 2 ss. 5(1)(a), 5(3)(c), 15(b), 19(3), 23 AMLO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Remedial and enhancement measures by the bank, no previous disciplinary record under the AMLO, cooperation with the regulator.
Published
23 Sep 2022

Original amount 11,000,000 HKD, converted at the ECB reference rate of 23 Sep 2022.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 23 Sep 2024 · Direct link

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20 Sep 2022 a large US broker-dealer and wealth managerSEC: $35 million against US wealth manager over unsafe disposal of hard drives USAData breaches and data securityanonymised €35m

From 2015, the firm had thousands of hard drives and servers containing data on around 15 million customers decommissioned by a moving company with no experience in data destruction; the devices were resold unencrypted and offered online. In addition, 42 servers with unencrypted customer data went missing. The penalty was imposed by the US Securities and Exchange Commission (SEC).

What organisations can take from it

Disposal of data carriers is a matter for senior management: engage only certified service providers, require proof of destruction and actually activate the encryption that is available.

Relevance to training and awareness

Secure disposal of data carriers and management of service providers

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Data protection · Data breaches and data security
Legal basis
Regulation S-P (Safeguards Rule und Disposal Rule)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Culpability
negligent
Published
20 Sep 2022

Original amount 35,000,000 USD, converted at the ECB reference rate of 20 Sep 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 20 Sep 2024 · Direct link

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13 Sep 2022 a Danish major bankCentral Bank: €1.82m fine against Danish major bank – gaps in transaction monitoring IrelandInternal controlsanonymised €1.82m

Outdated data filters in the group-wide automated monitoring system excluded certain customer categories of the Irish branch from anti-money laundering transaction monitoring for almost nine years (2010–2019); between 2015 and 2019, 348,321 transactions went unmonitored although the bank had known of the problem since 2015. The Central Bank issued a reprimand and imposed allegedly €1,820,000 after a 30% settlement discount (base amount €2.6m) – the first sanction against an institution operating in Ireland only through a passported branch.

What organisations can take from it

Group-wide monitoring systems must be calibrated to the law of each country and their filters reviewed regularly.

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; Administrative Sanctions Procedure
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Settlement with a 30% discount; breaches admitted.
Published
15 Sep 2022

Checked against the official source on 7 Oct 2026 · Version 2 · Company name anonymised since 13 Sep 2024 · Direct link

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2 Sep 2022 a Japanese payment services providerPayment provider: order over anti-money laundering and outsourcing failings JapanCustomer due diligenceanonymised Order

The funds transfer provider received a business improvement order under Art. 55 of the Payment Services Act. An on-site inspection had found inadequate governance with insufficient management involvement, no oversight of the core processes outsourced to its parent company (including sub-outsourcing and further sub-outsourcing it was unaware of), breaches of the anti-money laundering law, such as not checking customers’ transaction purpose and occupation, and gaps in meeting the supervisory AML guidelines, such as having no rules for identifying suspicious transactions. The company had to submit an improvement plan by 3 October 2022 and report quarterly on its implementation.

What organisations can take from it

A firm that outsources customer due diligence to its parent company remains responsible for how it is carried out and must oversee it, including any subcontractors.

Relevance to training and awareness

Customer due diligence and oversight of outsourced processes

Authority / court
Regionales Finanzbüro (Local Finance Bureau), Aufsicht im Auftrag der Financial Services Agency (FSA, 金融庁)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Payment Services Act (資金決済に関する法律) Art. 55, Art. 50; Act on Prevention of Transfer of Criminal Proceeds (犯罪収益移転防止法); Guidelines for AML/CFT der FSA
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Published
2 Sep 2022

Checked against the official source on 14 Oct 2026 · Company name anonymised since 2 Sep 2024 · Direct link

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