Top AML Fines 2022-2025: Key Trends & Compliance Insights

Over the past several years, anti-money laundering (AML) enforcement has undergone a paradigm shift. Financial institutions across the globe are being held to an increasingly higher standard as regulatory bodies adopt a zero-tolerance approach toward non-compliance. This shift is reflected in the surging number and size of recent AML fines, with billions of dollars levied against banks, fintech firms, and virtual asset service providers from 2022 through early 2025.

According to recent reports, AML enforcement actions are not only more frequent but also more diversified in scope, targeting a broader range of institutions and risk typologies, from traditional banks to cryptocurrency exchanges, gaming operators, and fintech startups.

These enforcement actions aren't just about punishing past misconduct, they signal a global crackdown on weak compliance cultures, inadequate AML programs, and poor governance.

Objectives of this Article

This article serves three core purposes:

• Showcase key recent AML fines from 2022 to 2025, highlighting the largest anti money laundering penalties and notable enforcement actions across jurisdictions;

• Identify common themes, patterns, and deficiencies that repeatedly lead to enforcement;

• Provide practical best practices for financial institutions to proactively enhance their AML programs and avoid similar penalties in the future.

What Are AML Fines and Why Are They Imposed?

An AML fine is a monetary penalty imposed by a regulatory authority or court against an individual or institution found to be in breach of anti-money laundering laws or regulations. These laws exist to prevent the use of the financial system for illicit purposes, such as the laundering of proceeds from crime, terrorist financing, or sanctions evasion.

AML fines are authorized under various legal frameworks depending on jurisdiction:

• In the United States, AML enforcement is primarily governed by the Bank Secrecy Act (BSA) and USA PATRIOT Act, with anti money laundering penalties enforced by bodies such as FinCEN, OFAC, and the Department of Justice.

• In the UK, enforcement arises under the Money Laundering Regulations 2017 (MLRs) and the Proceeds of Crime Act 2002 (POCA), with the Financial Conduct Authority (FCA) being a key enforcer.

• In the EU, the Sixth Anti-Money Laundering Directive (6AMLD) harmonizes criminal penalties and expands liability to legal persons.

AML fines serve two purposes:

1. Punishment for breaches of legal obligations;

2. Deterrence to compel institutions to uphold strong AML controls and deter others from similar failures.

Common Triggers for AML Enforcement

Most AML enforcement actions stem from repeatable and preventable weaknesses. The following deficiencies frequently appear in regulatory findings:

1. Failure to Implement an Effective AML Program

Example: In 2024, TD Bank in the U.S. was fined $3.09 billion for systemic compliance failures and weak AML governance structures, one of the largest AML penalties in recent history.

2. Inadequate Know Your Customer (KYC) and Customer Due Diligence (CDD)

Example: In 2023, Santander UK was fined £107.7 million by the FCA for significant and prolonged weaknesses in its KYC/CDD controls, particularly in monitoring business banking customers.

3. Ignoring Red Flags or Failing to File Suspicious Activity Reports (SARs)

Example: In 2022, Danske Bank was penalized $2 billion by U.S. and Danish authorities for knowingly allowing suspicious transactions to flow through its Estonian branch without filing proper reports.

Timeline of Major AML Fines (2022–2025)

Over the past four years, global regulators have issued increasingly significant AML criminal penalties, signaling a dramatic escalation in enforcement intensity. The timeline from 2022 to early 2025 illustrates not just a surge in dollar amounts, but also an evolution in regulatory scope, targeted sectors, and geographic reach.

Let’s break it down by year, starting with the most recent data.

AML Fines in 2025

While we are only months into 2025, early enforcement actions already indicate a strategic pivot by regulators toward emerging financial platforms and digital service providers, namely fintechs, broker-dealers, and Neobanks. These actions suggest a proactive regulatory posture aimed at newer risk vectors in the financial system.

1. LPL Financial – $3 Million Fine

In March 2025, U.S.-based broker-dealer LPL Financial agreed to a $3 million settlement with the Financial Industry Regulatory Authority (FINRA) for failures in its AML program. Specifically, LPL’s systems failed to detect and report suspicious activity tied to penny stock trading, raising concerns about both customer due diligence (CDD) and suspicious activity report (SAR) obligations.

2. Block Inc. (Cash App) – $1 Million

In January 2025, Block Inc., the parent company of Cash App, faced significant regulatory actions due to violations of the Bank Secrecy Act (BSA) and AML laws. A coordinated effort by 48 state financial regulators resulted in an $80 million fine against Block Inc.

The regulators identified that Cash App had insufficient policies for monitoring and preventing money laundering activities on its platform. As part of the settlement, Block Inc. agreed to hire an independent consultant to assess and enhance its BSA/AML compliance program.

3. De Volksbank (Netherlands)

In February 2025, the Dutch Central Bank (DNB) imposed a €2.5 million fine on De Volksbank N.V. for serious shortcomings in its AML compliance systems between 2018 and 2020. According to DNB, the bank failed to adequately assess the risk of money laundering and terrorist financing across its customer base.

Key failings included:

• Incomplete or outdated customer risk profiles;

• Lack of transaction monitoring in line with customer risk;

• Deficient internal oversight of AML processes.

The DNB emphasized that these deficiencies "seriously undermined the effectiveness of the fight against financial crime."  

AML Fines in 2024

2024 marked a major evolution in AML enforcement globally. While legacy banks remained under scrutiny, regulators cast a wider net imposing substantial fines on neobanks, digital lenders, gaming operators, and payment processors.

1. TD Bank (USA) – $3.09 Billion

In one of the largest AML penalties ever, TD Bank was fined over $3 billion by U.S. authorities for long-standing AML compliance failures, including the enabling of drug trafficking operations by turning a blind eye to red flags in high-volume, suspicious transactions.

2. City National Bank (USA) – $65 Million

This midsized U.S. bank was fined by the Office of the Comptroller of the Currency (OCC) and FinCEN for repeated violations related to inadequate SAR filings and failure to monitor international wire activity, especially involving high-risk jurisdictions.

In January 2024, the Office of the Comptroller of the Currency (OCC) imposed a $65 million civil money penalty on City National Bank for serious deficiencies in its risk management and internal controls. The bank was found to have failed in establishing effective oversight for managing operational and compliance risks, leading to non-compliance with the Bank Secrecy Act (BSA).

The OCC also found the bank to be in violation of OCC Guidelines Establishing Heightened Standards for large national banks, and issued a cease-and-desist order, compelling the bank to undertake comprehensive corrective actions. These included overhauling its AML compliance framework, improving internal controls, and strengthening its compliance risk management practices.

3. SkyCity Adelaide (Australia) – $67 Million

In 2024, SkyCity Adelaide was fined A$67 million after the Federal Court of Australia ruled that the casino operator failed to meet its AML obligations under the AML/CFT Act. SkyCity was found to have lacked adequate systems for monitoring suspicious transactions and failed to implement effective customer due diligence (CDD). This ruling follows years of investigation by the Australian Transaction Reports and Analysis Centre (AUSTRAC).

AML Fines in 2023

1. Binance – $4.3 Billion

In 2023, Binance agreed to a $4.3 billion resolution with U.S. authorities after pleading guilty to violating federal charges related to AML and sanctions breaches. The company and its CEO admitted to enabling illegal transactions and failing to establish adequate AML controls, ultimately resulting in one of the biggest AML fines for a cryptocurrency exchange. This settlement includes criminal and civil penalties, requiring Binance to overhaul its compliance measures.

2. Santander UK – £107.7 Million

In 2023, Santander UK was fined £107.7 million by the Financial Conduct Authority (FCA) for repeated failures in its AML controls. The FCA identified serious weaknesses in the bank's AML procedures, including inadequate systems to monitor and report suspicious activity. Despite previous warnings, Santander failed to address these issues, resulting in significant regulatory penalties.

AML Fines in 2022

1. Danske Bank – $2 Billion

In 2022, Danske Bank pleaded guilty to fraud-related charges for its involvement in a multi-billion-dollar money laundering scheme that accessed U.S. financial institutions.

The bank was fined $2 billion after it was found that over a span of several years, billions of dollars in suspicious transactions flowed through its Estonian branch, violating U.S. laws and AML regulations. This case marked a significant enforcement action due to the magnitude of the violations.

2. NatWest (UK) – £264.8 Million

In 2022, NatWest (UK) was fined £264.8 million for failures in monitoring and scrutinizing suspicious transactions between 2012 and 2016. The bank failed to properly manage cash deposits for its customer, Fowler Oldfield, a jewelry business, which resulted in approximately £365 million in deposits, including £264 million in cash.

Despite clear red flags, such as unusual deposits and unverified transaction patterns, NatWest's monitoring systems did not act appropriately, leading to money laundering activity. This case marked the FCA's first criminal prosecution under the Money Laundering Regulations.

3 Trends in AML Enforcement (2022–2025 Data)

These trends and criteria reflect the evolving landscape of AML enforcement and underline the importance of maintaining robust compliance systems.

1. Shift Toward Fintech and Digital Banks

Over the last few years, there has been a notable shift towards regulating fintech and digital banks. With their rapid growth, these institutions have faced significant AML scrutiny, especially as regulators tackle the challenges of monitoring digital asset transactions and untraditional business models. Fines against companies like Binance (cryptocurrency exchanges) and Block Inc. demonstrate how the industry is under increasing pressure to comply with traditional financial laws.

2. Stronger Enforcement of Beneficial Ownership Transparency

Regulators globally are cracking down on the non-disclosure of beneficial ownership. This trend has gained significant traction, with countries like the EU and the U.S. passing stringent laws requiring financial institutions to collect and disclose accurate beneficial ownership information. Failure to comply has resulted in hefty penalties, as seen in recent fines against major financial institutions.

3. Increase in Personal Liability for Executives and Compliance Officers

Another key trend in 2022–2025 enforcement is the increasing personal liability for executives and compliance officers who fail to ensure AML compliance. Regulators are targeting individuals behind the institutions, as evidenced by actions taken against high-ranking officials at organizations like Deutsche Bank and HSBC. This shift underscores the responsibility executives bear for ensuring robust AML systems are in place.

4. Regulators Leveraging Technology (AI, Data Analytics)

Regulatory authorities are increasingly utilizing artificial intelligence (AI) and data analytics to monitor and detect suspicious activities in real-time. These technologies allow for the analysis of vast amounts of transaction data, enhancing the ability to detect patterns associated with money laundering.

Financial institutions are expected to adopt these tools to remain compliant, as regulators continue to use them to identify and penalize violations more efficiently.

How AML Fines Are Determined

AML fines are determined through a combination of regulatory and judicial factors. The criteria for calculating these penalties are multifaceted and often depend on:

1. Severity and Duration of the Violation

2. Institutional Size and Scop

3. Degree of Cooperation During Investigation

4. Prior Compliance History

5. Role of Settlements and Deferred Prosecution Agreements (DPAs)

AML Red Flags and Common Regulatory Compliance Failures

AML red flags include large or rapid transfers to high-risk jurisdictions, transactions involving shell companies, unusual structuring of deposits or withdrawals, and inconsistent customer behavior.

Failure to monitor these activities often results in violations. Common regulatory failures include inadequate customer due diligence (CDD), not conducting periodic reviews, overlooking suspicious activity reports (SARs), and failing to implement effective transaction monitoring systems.

Top 8 Best Practices for Avoiding AML Fines and Penalties

Financial institutions and businesses must avoid anti-money laundering fines and penalties. It is crucial to maintain their integrity and comply with regulations. Implementing effective AML practices is essential for safeguarding against illicit financial activities. Here are some best practices to help you avoid anti-money laundering fines and penalties:

1. Implement robust KYC/AML programs

2. Ensure effective transaction monitoring

3. Conduct regular employee training

4. Leverage advanced technology for real-time monitoring

5. Report suspicious activity promptly

6. Maintain accurate and updated beneficial ownership information

7. Regularly audit compliance programs

8. Collaborate with regulators and industry bodies

Conclusion

In conclusion, bank fines, penalties, and sanctions for anti-money laundering violations can significantly challenge your financial institution's operations. Safeguarding compliance with AML regulations requires integrating a robust platform like FOCAL AI into your compliance technology infrastructure.

FAQs

Q1. What are AML fines?

AML fines are financial penalties imposed on institutions that fail to comply with Anti-Money Laundering regulations. These bank fines are issued by regulatory authorities when institutions fail to implement sufficient measures to detect, prevent, or report illicit financial activities. Non-compliance may include shortcomings in customer due diligence, lack of reporting suspicious transactions, or inadequate monitoring systems to prevent money laundering.

Q2. Which Countries Are Fining the Most?

The United States and European nations, especially the UK and Germany, are among the top countries enforcing AML regulations. These regions lead in imposing substantial AML criminal penalties due to their robust regulatory frameworks and rigorous enforcement measures. The increase in AML fines reflects the global shift towards strengthening financial crime prevention across sectors.

Q3. What is the largest AML fine to date?

The largest AML penalty recorded to date is a $4.3 billion fine, imposed on Binance in 2023. Amongst other biggest AML fines, this one resulted from violations of AML and Counter-Terrorism Financing rules, alongside sanctions breaches in the United States. This case exemplifies the heightened attention given to cryptocurrency exchanges in regulatory enforcement actions aimed at combating financial crime.