Skip to main content Skip to navigation

Now available: The State of Financial Crime 2025

The biggest AML fines in 2024

AML Compliance Knowledge & Training

Throughout 2024, financial regulators worldwide continued to demonstrate their intent to crack down on non-compliance with anti-money laundering and countering the financing of terrorism (AML/CFT) rules. Firms that breached these regulations, including high-profile institutions with significant public profiles, were met with substantial monetary penalties. These costs and the reputational fallout that came with them reinforced the business case for prioritizing compliance. 

This article explores the AML fines issued in 2024, looking at the failings that caused them and highlighting areas firms should look to address. While some sectors received higher penalties than others, the most significant fines and the number of firms and industries to have paid them demonstrate the importance of maintaining an effective AML compliance program across all regulated sectors. 

AML fines in 2024

Several sectors were subject to significant regulatory action last year. While AML fines are normally issued several years after regulatory breaches occur, these were the most heavily fined sectors in 2024: 

  1. Banking – $3.2 billion+ in fines 
  2. Cryptocurrency – $86 million+ in fines 
  3. Gambling – $69 million+ in fines 
  4. Payments – $46 million+ in fines 
  5. Trading and brokerage – $10 million+ in fines 

1. Banking – $3.2 billion+ in fines

Having received the second-highest AML fines in 2023, the banking sector saw a significant increase in penalties in 2024, with both large institutions and challenger or neo-banks receiving huge fines. In one high-profile case, a bank was fined billions of dollars by multiple regulators for several failings, including:  

  • A failure to update its compliance program to update known risks, such as money being funneled into high-risk jurisdictions. 
  • Failing to file suspicious activity reports (SARs) despite transactions having been red-flagged. This meant criminal groups, including drug and human traffickers, were able to move billions of dollars through the bank.  
  • Filing delayed or misleading currency transaction reports (CTRs). 
  • Not acting on red flags indicating employee involvement in financial crime. 

In the UK, two well-known challenger banks racked up almost $60 million in Financial Conduct Authority (FCA) fines between them: one for systemic problems with its sanctions screening solution and one for inadequate transaction monitoring processes. In two other cases, regulators mentioned a failure to carry out adequate due diligence on correspondent banking accounts as a reason for imposing large fines on institutions. Correspondent banking is often recognized as high-risk; the Financial Action Task Force (FATF), for example, recommends carrying out enhanced due diligence (EDD) on correspondent banking relationships. 

2. Cryptocurrency – $86 million+ in fines

In 2023, the cryptocurrency industry ranked first in our top AML enforcement actions list. Although the amount it has had to pay in fines dropped in 2024, several crypto firms still received large fines. In one case, a firm was fined tens of millions of dollars for deficiencies in its transaction monitoring system, which led to a failure to detect $9 billion in suspicious payments. 

Another firm, despite having already been fined billions of dollars in 2023, received two further fines in 2024 for reasons including a failure to report transactions over regulatory thresholds. Sanctions breaches and taking on high-risk customers without conducting the necessary due diligence checks were further regulatory breaches mentioned in other crypto AML enforcement cases. 

3. Gambling – $69 million+ in fines

As in previous years, Australian gambling and entertainment firms suffered significant AML fines in 2024. One company was ordered to pay in the region of $70 million for allowing high-risk customers to use its casinos to obscure their source of funds (SOF) and for failing to apply risk-based controls to customers. Another casino, based in the US, was found to lack even basic AML controls and failed to file SARs and CTRs. 

Meanwhile, in the UK, a well-known betting firm was fined for having ineffective know-your-customer (KYC) EDD checks relative to its AML risks, inadequate risk ratings, and failing to screen customers against sanctions lists. Other causes of AML gambling fines included: 

  • Failing to report suspicious transactions linked to illegal betting. 
  • Poor customer due diligence (CDD) checks, including an overreliance on third-party information. 
  • Inadequate SOF checks. 
  • A failure to apply transaction reporting thresholds and triggers. 

4. Payments – $46 million+ in fines 

The payments sector was missing from our 2023 fines roundup but has returned to this year’s list thanks to a large penalty for a fast-growing FinTech firm. The business was fined tens of millions of dollars for significant weaknesses in its AML compliance measures, which included a failure to properly consider how its services could be used for money laundering or terrorist financing. This serves as a reminder to carry out effective business-wide risk assessments and apply a risk-based approach to compliance

5. Trading and brokerage – $10 million+ in fines

Although the fines received by trading and brokerage firms last year tended to be lower than in other sectors, such as banking, the number of companies subject to regulatory action was enough to see the sector complete our list of 2024’s top AML fines. 

More than one firm, including a subsidiary of a leading European bank, was charged with failing to file SARs on time. Others were criticized by regulators such as the Financial Industry Regulatory Authority (FINRA) for an inability to monitor and detect suspicious transactions or for a lack of written AML policies and procedures. In one case, a firm was found to have inadequate fraud prevention measures, allowing criminals to open accounts using fake or stolen identities. 

Webinar: Navigating global risks, AI, and key regulatory milestones in 2025

Unpack the results of our global survey on what compliance leaders think will shape 2025.

Sign up now

The AML violations with the biggest penalties

Across these sectors, several firms committed similar compliance failings, which led to regulatory enforcement action. Some of the most significant were: 

  • Sanctions violations: As global sanctions regimes continued to expand in the wake of ongoing geopolitical conflicts, the importance of effective sanctions screening became clear. Fines ensued for firms doing business with sanctioned entities, with both deliberate and inadvertent breaches resulting in regulatory action. 
  • Inadequate CDD: Risk-based due diligence is a cornerstone of compliance regimes worldwide. As in previous years, institutions that failed to apply the correct level of CDD, including EDD for higher-risk customers, were met with heavy monetary penalties. 
  • Failing to adequately monitor transactions: Across all sectors, transaction monitoring was a key issue in 2024. Firms using solutions that did not pick up on suspicious transactions and therefore allowed their services to be used for criminal purposes suffered the financial consequences. 
  • Improper SAR filing: Regulators punished firms that filed late or misleading SARs, or failed to file them at all. This underlines the importance of filing prompt and accurate reports and having appropriate transaction monitoring measures in place to support them. 

Recent and upcoming AML regulations to be aware of

Regulatory compliance is top of mind for many firms, who realise that rather than simply being a matter of checking the right boxes, audits can be time-consuming, resource-intensive, and potentially disruptive to business operations if firms aren’t properly prepared. In our latest global survey of compliance decision-makers, 55 percent cited completing a regulatory audit as one of their most significant challenges. 

A proactive approach, which includes anticipating legislative developments and understanding regulators’ expectations, is key to meeting compliance requirements efficiently. Below are some of the most important regulatory updates of 2024, and some upcoming changes you should look out for in the year ahead. The impact of recent and anticipated regulatory changes is explored in depth in our annual report, The State of Financial Crime 2025

Key changes in AML regulations in 2024

  • European Union: The EU’s long-anticipated AML package was adopted in May. This included a new set of regulations harmonizing AML regulation and enforcement across member states, such as by mandating regular National Risk Assessments, new public supervisory bodies, and asset registers. As part of the package, a new Europe-wide regulator, the Anti-Money Laundering Authority (AMLA), has been set up. 
  • United States: In August, the Financial Crimes Enforcement Network (FinCEN) tightened the regulatory obligations of real estate firms and investment advisers. 
  • United Kingdom: Measures under the Economic Crime and Corporate Transparency Act (ECCTA) came into effect in March. These aimed to better protect Companies House, the UK’s business register, from fraudulent entities and to allow it to share information with law enforcement. Since October, payment service providers have had to reimburse victims of authorized push payment (APP) fraud up to £85,000. 
  • Australia: The Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Amendment Act was passed in December. This extended regulatory oversight to designated non-financial businesses and professions (DNFBPs), such as lawyers and accountants, and updated CDD requirements.
  • Singapore: The Anti-Money Laundering and Other Matters Act was passed, giving law enforcement greater powers to prosecute financial crimes and aligning the gambling sector’s regulatory obligations with FATF standards. 

Upcoming AML regulations in 2025

  • United States: US-based firms should expect a resolution to the legislative back-and-forth over beneficial ownership reporting. From January 2024, the Corporate Transparency Act (CTA) required firms to submit information on their ultimate beneficial ownership (UBO) to FinCEN. However, a Texas judge deemed this “likely unconstitutional” in December and issued a nationwide injunction against the CTA. After initially granting an emergency stay of the injunction, the US Court of Appeals for the Fifth Circuit reinstated it in late December. The federal government has now applied to the Supreme Court, the highest court in the country, for a stay, and its decision will determine whether firms must complete UBO filings. 
  • European Union: With its first chair appointed, AMLA will begin work in July. AMLA will coordinate national authorities to ensure the application of the EU’s AML framework and directly supervise certain high-risk firms operating across borders. Meanwhile, the Single Euro Payments Area (SEPA) Instant Credit Transfer (ICT) scheme will continue its expansion, with Turkey, Romania, Croatia, and Bulgaria all due to participate in 2025. 
  • Australia: A new confirmation-of-payee system, which aims to prevent fraud by verifying payee details before transactions are completed, is expected to be rolled out by FIs early on in 2025.  
  • Singapore: In mid-2025, the Monetary Authority of Singapore (MAS) and the Association of Banks in Singapore (ABS) will launch new electronic deferred payment systems (EDPs). This will support the country’s broader transition to e-payments, with corporate cheques gradually being phased out.  

How to avoid AML fines in 2025

As the size of some of the fines firms received demonstrates, AML failings can have a profound financial impact on firms. This is often compounded by the reputational damage these fines can cause. Consumers are less likely to do business with firms known for poor financial crime detection measures, with one study suggesting that global executives attribute 63 of their company’s market value to its reputation. 

To protect themselves from the immediate and long-term consequences of non-compliance, you should: 

The State of Financial Crime 2025

Read our annual report to explore the most important trends affecting the financial crime landscape and how firms can prepare for the year ahead.

Download now

Originally published 04 February 2025, updated 04 February 2025

Disclaimer: This is for general information only. The information presented does not constitute legal advice. ComplyAdvantage accepts no responsibility for any information contained herein and disclaims and excludes any liability in respect of the contents or for action taken based on this information.

Copyright © 2025 IVXS UK Limited (trading as ComplyAdvantage).