Anti-money laundering (AML) regulations play a critical role in maintaining the integrity of global financial systems. However, despite growing awareness and enhanced regulatory measures, every year, high-profile businesses and individuals find themselves on the receiving end of significant penalties for AML failures.
This annual report highlights the biggest AML fines each year, shedding light on the companies and institutions that failed to meet the rigorous standards set to prevent money laundering and other illicit financial activities.
From banks to gambling operators, the report explores the nature of these violations and the consequences for those involved.
We track the most notable fines in our comprehensive AML Fines Annual Report. Below are the largest fines for each year.
AML fines in 2024
- TD Bank - $3bn fine
- Nordea Bank - $35m fine
- Starling Bank - $29m fine
- MGM Grand & The Cosmopolitan - $7.45m settlement
- TD Bank - $6.7m fine
- Danske Bank - €6.3m settlement
- AIA Group - $2.9m fine
- Estate Agents - £1.6m fine
- Commerzbank - $1.5m fine
- Fairbrother & Darlow - $16k fine
Take a closer look at each of 2024's AML fines.
AML fines in 2023
- Binance: $4.3bn fine
- Crown Resorts: $450m fine
- Deutsche Bank: $186m fine
- Bank of Queensland: $50m capital penalty
- William Hill: £19.2m fine
- Guaranty Trust Bank UK Ltd: £7.6m fine
- ADM Investor Services International Ltd: £6.47m fine
- In Touch Games: £6.1m fine
- Royal Bank of Canada: $5.5m fine
- Al Rayan Bank: £4m fine
Take a closer look at each of 2023's AML fines.
AML fines in 2022
- Santander: £108m fine
- 888 UK Limited: £9.4m fine
- Ghana International Bank: £5.8m fine
- Javanshir Feyziyev: £5.6m fine
- TJM Partnership: £2m fine
- Robeco: €2m fine
- Danske Bank: €1.82m fine
- UK Estate Agents: £500k fine
- Southern Cross SICAV plc: €300k fine
- XNT Ltd: €245k fine
Take a closer look at each of 2022's AML fines.
AML fines in 2021
- NatWest: £265m fine
- HSBC: £64m fine
- MT Global: £23m fine
- Azeri PEP: £4m funds surrendered
- Richard Leahy: £2m settlement
- CLSA Premium: £560k fine
Take a closer look at each of 2021's AML fines.
AML fines in 2020
- DNB: £34.4m fine
- Deutsche Bank: £11.6m fine
- Betway: £11.6m fine
- Westpac: £700m fine
Take a closer look at each of 2020's AML fines.
AML fines of 2024: A closer look
1. TD Bank - $3bn fine
TD Bank agreed to pay $3 billion to settle charges of failing to monitor money laundering tied to drug cartels. This included a record $1.3 billion fine to the US Treasury and $1.8 billion to the US Justice Department, alongside a guilty plea for violating the Bank Secrecy Act.
More than $670 million was laundered through TD Bank between 2018 and 2024 due to inadequate transaction monitoring.
“I want to be clear, these systemic failures did not just create hypothetical vulnerabilities, but they resulted in actual, material harm to American citizens and communities. Time and again, unlike its peers, TD Bank prioritised growth and profit over complying with the law. The bank enabled drug trafficking.”
2. Nordea Bank - $35m fine
Nordea Bank paid $35 million following an NYDFS probe that found inadequate AML controls allowed high-risk transactions linked to Russian and Azerbaijani funds between 2008 and 2019. These compliance failures exposed billions to risk within New York’s financial system.
"International financial entities such as Nordea must safeguard against criminal activity in the global financial system, and for years Nordea failed in these respects."
3. Starling Bank - $29m fine
The FCA fined Starling Bank £28.96 million for weak financial sanctions screening and breaching an agreement to avoid high-risk accounts. Despite rapid growth, its financial crime controls lagged, with over 54,000 high-risk accounts opened from 2021 to 2023. An internal review in January 2023 revealed serious flaws in Starling’s screening system since 2017, leaving it exposed to financial crime.
"Starling’s financial sanction screening controls were shockingly lax. It left the financial system wide open to criminals and those subject to sanctions. It compounded this by failing to properly comply with FCA requirements it had agreed to, which were put in place to lower the risk of Starling facilitating financial crime."
4. MGM Grand & The Cosmopolitan - $7.45m settlement
MGM Grand and The Cosmopolitan settled for $7.45 million after failing to report suspicious transactions tied to an illegal sports betting scheme. Former MGM President Scott Sibella admitted to not reporting the scheme, enabling criminal proceeds to flow undetected in their casinos.
5. TD Bank - $6.7m fine
Canada’s FINTRAC fined TD Bank a record C$9.2m ($6.7m) for AML non-compliance after a 2023 review found failures in monitoring high-risk accounts. CEO Bharat Masrani acknowledged deficiencies in the bank’s AML programme, which faced scrutiny from both Canadian and US regulators.
6. Danske Bank - €6.3m settlement
Danske Bank has reached a final settlement with French authorities, agreeing to pay €6.3 million following investigations into suspected money laundering at its now-closed Estonian unit. This amount is significantly lower than the $2 billion the bank paid in a similar settlement in the United States.
The investigations stemmed from a 2018 scandal in which Danske Bank's Estonian branch was at the centre of one of Europe's largest money laundering cases, involving around €200 billion laundered by suspicious customers.
7. AIA Group - $2.9m fine
AIA Group was fined HK$23m ($2.9m) by Hong Kong’s Insurance Authority for AML system failures, including delays in identifying politically exposed persons. Despite no evidence of money laundering, AIA cooperated fully and submitted a remediation report as required.
8. Estate Agents - £1.6m fine
HMRC fined 254 estate agencies over £1.6 million for failing to register or re-register for AML compliance, with penalties ranging from £1,500 to £50,000. A follow-up list was planned to address further breaches, underscoring HMRC’s strict approach to AML compliance.
“Registering with HMRC is one of the most basic requirements of the Money Laundering Regulations (MLR). However, so many businesses fail to complete this simple obligation, either by ignorance or by believing that the regulations simply do not apply to them.”
9. Commerzbank - $1.5m fine
Germany's financial watchdog, BaFin, has penalised Commerzbank with a fine of 1.45 million euros ($1.5m) for failing to fulfil its anti-money laundering responsibilities. BaFin stated that both Commerzbank AG and its predecessor, Comdirect Bank AG, neglected their supervisory duties. The bank failed to update customer data promptly and implement sufficient security measures, leading to inadequate due diligence in three instances, thus breaching anti-money laundering obligations.
10. Fairbrother & Darlow - $16k fine
The SRA fined Fairbrother & Darlow £16,000 for nearly six years of AML compliance failures, citing missing risk assessments and policies despite a 2020 compliance declaration. While the firm cooperated and took corrective action, the SRA noted risks posed to public confidence in the legal profession.
AML fines of 2023: A closer look
1. Binance - $4.3bn fine
Binance pleaded guilty and agreed to pay a $4.3bn fine after admitting to money laundering, unlicensed money transmitting, and sanctions violations. CEO Changpeng Zhao resigned and was fined $50m for failing to maintain an effective AML program. The platform allowed illegal activities, including terrorist and cybercriminal transactions, by failing to implement KYC protocols and report suspicious activities.
2. Crown Resorts - $450m fine
Crown Resorts was fined $450m by AUSTRAC for historical AML breaches at its Melbourne and Perth casinos. The financial intelligence agency acknowledged the company's failure to assess money laundering and terrorist financing risks. The fine, approved by the Federal Court, was the third-largest corporate fine in Australian history.
3. Deutsche Bank - $186m fine
The Federal Reserve imposed a $186m fine on Deutsche Bank for inadequate efforts to address money laundering control issues. The bank was warned to prioritise resolving previously identified deficiencies, with further penalties possible if it failed to act. The issues stemmed from its dealings with Danske Bank’s Estonian branch, flagged as early as 2015.
4. Bank of Queensland - $50m capital penalty
The Bank of Queensland was given a $50m capital penalty for breaching prudential standards and failing to comply with AML laws. The bank was required to hold an additional $50m until it addressed regulators’ concerns and implemented a remedial action plan.
5. William Hill - £19.2m fine
William Hill and Mr Green were fined a record £19.2m for social responsibility and AML failures, including allowing customers to deposit large sums without proper checks. These lapses, particularly during the lockdown, led to serious concerns over the exploitation of vulnerable individuals. The Gambling Commission chose the large fine instead of licence suspension after the companies took swift corrective action.
“When we launched this investigation, the failings we uncovered were so widespread and alarming serious consideration was given to licence suspension. However, because the operator immediately recognised their failings and worked with us to swiftly implement improvements, we instead opted for the largest enforcement payment in our history.”
6. Guaranty Trust Bank UK Ltd - £7.6m fine
Guaranty Trust Bank UK Ltd was fined £7.6m for serious weaknesses in its AML systems, including inadequate customer risk assessments and due diligence on high-risk clients. The fine was increased due to the bank's previous offences, and the bank settled without disputing the FCA's findings.
7. ADM Investor Services International Ltd - £6.47m fine
ADM Investor Services International Ltd. was fined £6.47m by the FCA for inadequate AML controls. The company’s operations involved clients classified as politically exposed persons, raising the risk of money laundering, which was not sufficiently mitigated.
8. In Touch Games - £6.1m fine
In Touch Games was fined £6.1m for social responsibility and AML failings, including failing to interact with a customer for seven weeks despite erratic play patterns. The operator, which had faced previous fines, was warned that further action would be taken for repeat offences.
"Considering this operator’s history of failings, we expected to see significant improvement when we carried out our planned compliance assessment. Disappointingly, although many improvements had been made, there was still more to do. This £6.1m fine shows that we will take escalating enforcement action where failures are repeated, and all licensees should be acutely aware of this."
9. Royal Bank of Canada - $5.5m fine
The Royal Bank of Canada was fined C$7.48 million ($5.5m) for failing to report suspicious transactions and lacking adequate AML safeguards. The bank missed 16 reports out of 130 reviewed, raising concerns about its internal procedures and regulatory effectiveness.
10. Al Rayan Bank - £4m fine
Al Rayan Bank was fined £4m by the FCA for failing to conduct proper wealth checks on high-risk customers and not maintaining adequate due diligence records. Despite warnings from its Second Line of Defence, the bank had not addressed AML shortcomings, leading to the fine.
“Maintaining strong defences against the evolving threats of financial crime is an essential part of our business plan and is being led by the new board and executive team.”
AML fines of 2022: A closer look
1. Santander - £108m fine
The FCA fined Santander nearly £108m for failures in its business bank division's AML systems. Between 2012 and 2017, the bank's systems were unable to properly verify customer information for 560,000 business clients, exposing it to a significant risk of money laundering. Santander did not dispute the regulator's findings, which allowed it to receive a 30% discount on the fine.
“Santander’s poor management of their anti-money laundering systems and their inadequate attempts to address the problems created a prolonged and severe risk of money laundering and financial crime.”
2. 888 UK Limited - £9.4m fine
888 UK Limited was fined £9.4m by the UK Gambling Commission for failing to protect players at risk of harm and for inadequate customer due diligence. The company allowed customers to gamble large sums without proper checks on their source of funds, breaching the Gambling Commission's formal guidance.
"[The] fine is one of our largest to date, and all should be clear that if there is a repeat of the failures at 888, then we have to seriously consider the suitability of the operators to uphold the licensing objectives and keep gambling safe and crime-free."
3. Ghana International Bank - £5.8m fine
Ghana International Bank (GHIB) was fined £5.8m by the FCA for poor AML controls. The bank was found to have provided correspondent banking services without properly assessing or identifying the risks posed by its customers. While no actual money laundering was detected, the risks were considered significant.
4. Javanshir Feyziyev - £5.6m fine
A UK court ordered Azerbaijani politician Javanshir Feyziyev and his family to forfeit £5.63m from a complex money-laundering scheme known as the "Azerbaijani laundromat." The funds were brought into the UK as part of a larger money-laundering operation exposed in 2017, involving over 16,000 private transactions between 2012 and 2014.
"This is a substantial forfeiture of money laundered through the Azerbaijan laundromat, and our success highlights the risk to anyone who uses these schemes. We could recover these millions without proving the exact nature of the original criminal activity. We will continue to use civil powers to target money entering the UK via illegitimate means."
5. TJM Partnership - £2m fine
TJM Partnership, a family office broking firm, was fined £2m for failing to implement effective systems to prevent financial crime. The company was also found to have engaged in illegal trading for clients of Bermuda-based Solo Group, facilitating withholding tax claims in Denmark and Belgium.
6. Robeco - €2m fine
Robeco was fined €2m by the AFM for insufficient customer checks related to money laundering. Despite managing over 250,000 clients, Robeco only flagged two clients as high-risk, which raised concerns with the Dutch financial regulator about the company's AML compliance.
7. Danske Bank - €1.82m fine
The Central Bank of Ireland imposed a €1.82m fine on Danske Bank for transaction monitoring failures in its Dublin branch between 2010 and 2019. The bank's automated monitoring system failed to monitor transactions for certain high-risk customer groups, leading to a serious gap in AML controls.
8. UK Estate Agents - £500k fine
HMRC fined 68 estate agents a total of £500k for non-compliance with AML regulations between January and March 2022. This enforcement highlighted ongoing issues with AML compliance in the sector, with HMRC emphasising the need for improved standards.
"We are determined to create a level playing field for businesses who play by the rules. That means taking action against the minority of businesses who fail to fulfil their legal responsibilities under the money laundering regulations."
9. Southern Cross SICAV plc - €300k fine
Southern Cross SICAV plc was fined €300k by the FIAU for several AML failures, including not obtaining sufficient information on the source of wealth or funds from its customers. The company also made questionable investments in its customers' businesses without clear justification, violating AML regulations.
"There was no clear rationale as to why the company was investing in the business of its customers and whether this was in line with the prospectus and the customary business of the company.”
10. XNT Ltd - €245k fine
XNT Ltd. was fined €244,679 by the FIAU for failing to conduct proper customer due diligence. The company did not assess the information required for its business relationships and had inadequate screening policies. Additionally, concerns were raised about the company's MLRO, who was found to lack understanding of the company's AML policies and controls.
AML fines of 2021: A closer look
1. NatWest - £265m fine
NatWest was fined £264.8m after being convicted of three anti-money laundering (AML) offences. This fine marked the FCA's first criminal charges against a firm for AML failures. Between 2012 and 2016, NatWest failed to monitor the activities of Fowler Oldfield, a jewellery firm that deposited £365 million, including £264 million in cash. Red flags were raised by bank employees, but no action was taken. The bank's transaction monitoring system also misclassified some cash deposits as cheques, which led to inadequate monitoring.
2. HSBC - £64m fine
HSBC was fined £63.9m for "unacceptable failings" in its AML systems between 2010 and 2018. The FCA found that the bank did not adequately monitor for terrorist financing and money laundering until 2014 and failed to properly assess new risks after 2016. The bank accepted the charges and settled, reducing the fine from £91m.
"HSBC's transaction monitoring systems were not effective for a prolonged period despite the issue being highlighted on numerous occasions. These failings are unacceptable and expose the bank and community to avoidable risks, especially as the remediation took such a long time."
3. MT Global - £23m fine
MT Global Limited received a £23m fine from HMRC for major AML breaches between 2017 and 2019. The company failed to meet fundamental requirements, including customer due diligence, risk assessments, and maintaining proper records. This fine set a new record for HMRC, exceeding the previous £7.8m penalty.
"We're here to help businesses protect themselves from those who would prey on their services. That includes taking action against the minority who fail to meet their legal obligations under the regulations as this record fine clearly shows."
4. Azeri PEP - £4m funds surrendered
Suleyman Javadov, a politically exposed person (PEP) with ties to Azerbaijan's ruling elite, agreed to forfeit £4m linked to the Azerbaijan Laundromat money laundering scheme. The National Crime Agency (NCA) successfully applied for account freezing orders on Javadov's bank accounts in 2018-2019, and the £4m forfeiture settled the claim.
"This result is a significant success for the UK – £4m for the public purse – following the first case seeking forfeiture of funds relating to the so-called Azerbaijan Laundromat. It follows a challenging and complex NCA investigation lasting more than two years, which resulted in Javadov agreeing to settle rather than face a court battle. Anyone who used the Azerbaijan Laundromat should not rest easy, as your assets in the UK are potentially recoverable."
5. Richard Leahy - £2m settlement
London-based property developer Richard Leahy agreed to settle a civil recovery claim by forfeiting nearly £2m in assets. The National Crime Agency (NCA) alleged Leahy was involved in various criminal activities, including money laundering and marijuana cultivation, spanning over 15 years. The settlement involves three London properties and over £1.1m in cash.
"This is a great result, recovering nearly £2m that will go back into the public purse and be used to help fight criminal activity. Settlements in civil cases offer good value to the taxpayer, avoiding often lengthy and costly legal battles while freeing up our investigators and legal team to pursue other casework.”
6. CLSA Premium - £560k fine
CLSA Premium, a multi-national foreign exchange company, was fined over £560,000 by New Zealand's Financial Markets Authority. The Auckland branch was found to have bypassed necessary know-your-customer procedures. The company failed to terminate business relationships with customers who refused to provide transparency about the origin of their funds. A judge concluded that company directors actively obstructed compliance managers, allowing suspicious transactions, including deposits of £36.2m and £30m from just two clients, to proceed.
AML fines of 2020: A closer look
1. DNB - £34.4m fine
Norway’s largest bank, DNB, was fined 400 million kroner (£34.4m) by Oslo's Financial Supervisory Authority for breaching anti-money laundering laws. The fine is unrelated to any direct suspicions of money laundering but stems from DNB’s poor compliance with Norway's Anti-Money Laundering Act. This follows a previous investigation into the bank for alleged money laundering activities tied to an Icelandic fishing company in Namibia.
2. Deutsche Bank - £11.6m fine
Deutsche Bank was fined €13.5m for failing to report suspicious transactions related to the Danske Bank money-laundering scandal. The bank failed to alert authorities on over 600 occasions, and much of the $200bn in suspicious transactions that passed through Danske Bank's Estonian unit were routed through Deutsche Bank. The bank denied any criminal misconduct on its part.
3. Betway - £11.6m fine
Betway, an online gambling company, was fined a record £11.6m by the Gambling Commission for failing to protect vulnerable customers and for money laundering violations. The investigation found that Betway allowed £5.8m to pass through its business that could reasonably be suspected as proceeds of crime. The company also failed to carry out sufficient social responsibility checks on VIP customers.
"The actions of Betway suggest there was little regard for the welfare of its VIP customers or the impact on those around them."
4. Westpac - £700m fine
Westpac, Australia's second-largest bank, agreed to a settlement of AUD 1.3 billion (£700m) following a money-laundering scandal. The breach involved the bank’s systems being used to facilitate payments for child abuse material without raising red flags. Westpac self-reported some breaches to Australia’s financial intelligence agency, Austrac, in 2019. This fine matches the record AUD 700m penalty faced by Commonwealth Bank in 2018 for similar AML violations.
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