For years the U.S. has led the way in imposing major anti-money laundering (AML) fines, but regulators in Europe have recently started taking a much tougher line.
Money laundering has consistently been a key area of focus for enforcement action, and alongside sanctions and tax evasion it attracts the largest fines for financial crime failures
Number of fines issued> U.S. $1 million
Value of fines levied*
Total global fines levied for AML failings, which dropped in 2019, show some signs of recovering in 2020. The number of fines fell 14%, and fine values 86%, between 2018 and 2019 but rose again in the first half of 2020 following two substantial fines imposed in Europe.
Hover over the chart to learn more.
A brief history of money laundering fines
Number of fines
Fine values*
Customer due diligence, AML management, suspicious activity monitoring and compliance oversight are the most frequently, cited failings, something that is consistent across all regions globally.
AML Management
Customer Standard Due Diligence/Monitoring
Suspicious Activity Monitoring
Compliance Monitoring and Oversight
Record Keeping
Systems and Controls
Regulatory Reporting
Customer Enhanced Due Diligence/Monitoring
Staff Training and Competency
Risk Management
Client Onboarding
Internal Audit
Sanctions Management
Supervision of Relevant Persons
Management Information
Staff Recruitment
Third-Party Oversight
IT Governance
Where regulations are hitting hardest
Many global regulators have joined the U.S. in imposing significant fines for AML failures. Since the 2008 financial crisis, regulatory enforcement -- particularly of money laundering activities -- was at a high, with the U.S. leading the way in issuing fines. Though the U.S. regulators continue to issue the largest proportion of anti-money laundering fines, the ratio is decreasing as other regulators around the world become more active.
Hover over the map to view the total fine amounts in each jurisdiction
Duff & Phelps is a global advisor with extensive expertise in a wide range of financial crime prevention areas. Our global team of anti-money laundering specialists assists a wide range of regulated firms to improve their AML arrangements to mitigate risks, meet regulatory requirements, and avoid reputational damage and enforcement action.
Duff & Phelps’ Global Enforcement Review 2020 provides insights on global enforcement trends with a focus on the financial services industry. Combining our regulatory experience with analysis of enforcement penalties issued by key regulators around the globe, our aim is to assist firms in understanding the key risks to inform strategic, governance, risk and compliance programs. In compiling this research and analysis, we have drawn on Corlytics’ extensive RiskFusion Global Enforcement database for the period January 1, 2013 to June 30, 2020. Corlytics is a world leader in determining of regulatory risk impact. For more information visit http://www.corlytics.com
Corlytics prioritizes and selects penalties for inclusion in the database based on the following criteria:
Enforcement penalties are from high priority financial services regulators and cover enforcement actions against both firms and individuals.
Enforcement penalties greater than US$1 million or equivalent across all selected regulators. For individuals, the US$1 million threshold does not apply.
All enforcement penalties (including those below US$1 million) for financial services firms and associated individuals with assets greater than US$25 billion.
Total Number of Failings 2015-2020
Jan 1- June 30
