Global Enforcement of
While anti-money laundering (AML) continues to dominate global financial crime regulation, enforcement activity is slowing as attention turns from banks to other financial institutions.
An Overview of Financial Crime Fines
The value of fines issued to financial services firms for AML failings reached a new recent low in 2021 compared to 2020 and represents just half of the peak figure achieved in 2018.
Number of fines issued
56 Total
5
Sanctions
6
Bribery
45
Money Laundering
61 Total
13
Sanctions
3
Bribery
45
Money Laundering
2018
2017
2019
65 Total
7
Sanctions
6
Bribery
52
Money Laundering
2020
2019
64 Total
7
Sanctions
23
Bribery
34
Money Laundering
2018
69 Total
11
Sanctions
34
Bribery
24
Money Laundering
2020
2019
2019
2018
2020
2017
2016
2018
2016
2017
Value of fines levied*
2020
2019
$4,675 mn Total
$27 mn
Sanctions
$2,427 mn
Bribery
$2,222 mn
Money Laundering
2019
2018
2020
$3,259 mn
Sanctions
$48 mn
Bribery
$444 mn
Money Laundering
2018
2017
2019
2020
$538 mn
Sanctions
$220 mn
Bribery
$3,297 mn
Money Laundering
2017
2016
2018
2019
2016
2017
2018
$31 mn
Sanctions
$7,497 mn
Bribery
$889 mn
Money Laundering
$3,751 mn Total
$4,054 mn Total
$3,947 mn Total
$102 mn
Sanctions
$1,709 mn
Bribery
$2,136 mn
Money Laundering
$8,417 mn Total
An Increase in Number of Fines
Globally, the number of fines issued in 2020 was
at the same level as those in 2019, however the
total value of AML enforcement fines is five times higher in 2020 following numerous substantial fines by Nordic regulators. Moreover, fine amounts
in 2021 may reach similarly high levels as previous years, with the total value of AML fines as of June 2021 nearly half of the 2020 and 2017 totals.
Hover over the chart to learn more.
A HISTORY OF AML FINES GLOBALLY
Number of fines
Fine values*
2016
2017
2018
2019
2020
2021
$2,222 mn
$444 mn
$3,297 mn
$2,136 mn
$889 mn
$1,626.6 mn
55
24
34
52
45
45
Jan 1- June 30
Key AML Findings
AML management, suspicious activity monitoring, customer due diligence, and compliance oversight are the most frequently cited failings, a trend that
is consistent across all regions globally. Firms should continue investing in these areas to minimize their financial crime risk and potential exposure to regulatory enforcement action.
U.S.
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
27
72
57
31
18
19
18
15
11
10
6
6
4
8
1
1
Customer Standard Due Diligence/Monitoring
AML Management
Suspicious Activity Monitoring
Compliance Monitoring and Oversight
Customer Enhanced Due Diligence/Monitoring
Regulatory Reporting
Risk Management
Systems and Controls
Staff Training and Competency
Client Onboarding
Record Keeping
Management Information
Staff Recruitment
Third-Party Oversight
Internal Audit
IT Governance
51
43
28
18
19
13
13
14
9
8
8
4
4
3
3
2
APAC
1
2
Sanctions Management
Supervision of Relevant Persons
Customer Standard Due Diligence/Monitoring
AML Management
Suspicious Activity Monitoring
Compliance Monitoring and Oversight
Risk Management
Record Keeping
Systems and Controls
Customer Enhanced Due Diligence/Monitoring
Supervision of Relevant Persons
Staff Training and Competency
Client Onboarding
Management Information
Third-Party Oversight
Regulatory Reporting
27
20
16
11
7
7
7
4
3
4
3
2
2
3
Where regulations are hitting hardest
2016
2017
2018
2019
2020
2021
Jan 1- June 30
2020
2019
2018
2017
2016
Global Regulators: Blockbuster fine in
the Netherlands underlines that the U.S.
no longer dominates AML penalty activity
Since the 2008 financial crisis, regulatory enforcement — particularly of AML activities — was at a high, with the U.S. historically leading the way in issuing fines. More recently, however, the Nordics and Australia have led the way and imposed record levels of enforcement penalties.
Forthcoming changes in EU AML/Countering
the Financing of Terrorism (CFT) legislation
(as proposed by the European Commission in July 2021), including the creation of a new EU AML/CFT supervisory authority, may lead to increased enforcement action and larger fines issued within the EU in the coming years.
U.S. as %
41%
$7.27 mn
France
$441.09 mn
United Kingdom
$3.74 mn
Ireland
$592.69 mn
U.S.
97%
U.S. as %
$19.32 mn
Singapore
$2.73 mn
France
$4.76 mn
United Kingdom
$3.74 mn
Ireland
$858.25 mn
U.S.
72%
U.S. as %
$1.12 mn
Singapore
$346.76 mn
France
$204.22 mn
United Kingdom
$7.45 mn
Ireland
$1,545 mn
U.S.
$2.59 mn
Hong Kong
$28.48 mn
Australia
58%
U.S. as %
$4.50 mn
Singapore
$74.80 mn
France
$1.22 mn
United Kingdom
$0.48 mn
Ireland
$1,909 mn
U.S.
$12.71 mn
Hong Kong
$442.99 mn
Australia
$1.35 mn
Switzerland
$4.36 mn
Luxembourg
$845.68 mn
Netherlands
45%
U.S. as %
$4.50 mn
Singapore
$4.36 mn
France
$127.94 mn
United Kingdom
$0.31 mn
Ireland
$199.09 mn
U.S.
$107.59 mn
Hong Kong
$0.27 mn
Luxembourg
$3.85 mn
Italy
$1.23 mn
Netherlands
$0.12 mn
Canada
15%
U.S. as %
$1.07 mn
Singapore
$0.21 mn
France
$47.45 mn
United Kingdom
$592.69 mn
U.S.
$356.9 mn
Hong Kong
$6.2 mn
Italy
$0.02 mn
Canada
$559.33 mn
Sweden
Hover over the map to view the total fine amounts in each jurisdiction
Focused on Financial Services
Kroll is a global advisor with extensive expertise in a wide range of financial crime prevention areas. Our global team of financial crime specialists assists a wide range of regulated firms to improve their frameworks and arrangements to mitigate risks, meet regulatory requirements, and minimize reputational damage and enforcement action.
About the Global Enforcement Review
Kroll’s Global Enforcement Review 2021 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, 2016, to December 31, 2021. Corlytics is a world leader in determining of regulatory risk impact.
For more information, visit here
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
$1 million (mn) or equivalent across all selected regulators. For individuals, the $1 mn threshold does not apply.
All enforcement penalties (including those below
$1 mn) for financial services firms and associated individuals with assets greater than $25 billion.
Anti-Money Laundering Regulation:
Shift in Focus
BREAKDOWN OF FAILINGS
2016
2017
2018
2019
2020
2021
Jan 1- June 30
2021
2020
2019
2017
2016
Total Number of Failings 2016-2021
Total Number of Failings 2016-2021
2018
Jan 1- June 30
12
5
6
1
1
3
3
1
0
1
0
0
0
4
0
0
7
5
6
4
5
1
2
3
2
2
2
2
2
1
0
14
3
12
9
3
1
4
6
4
4
2
2
0
1
1
0
24
9
19
14
6
6
7
3
4
3
1
2
1
1
0
1
5
3
3
1
2
8
1
1
1
0
0
0
1
1
0
0
10
11
2
1
2
1
0
0
1
0
0
0
0
0
Global Total 2016-2021
UK + EU
U.S.
UK + EU
Click to explore the total number of failings by type, year, or region
Global Total 2016-2021
Total Number of Failings 2016-2021
2021*
*Jan 1- June 30
13
8
6
2
3
0
0
0
0
2
2
0
0
0
0
2020
12
6
4
0
3
2
2
1
1
1
2
0
0
1
0
0
2019
6
8
5
6
3
4
3
4
3
3
0
1
1
0
2
0
2018
6
4
5
6
5
4
4
4
3
2
1
2
2
1
1
1
2017
6
3
4
3
3
2
2
2
2
0
1
1
1
1
0
1
2016
8
14
4
2
1
3
1
0
0
0
0
0
0
1
0
0
1
1
0
0
0
0
0
Total Number of Failings 2016-2021
2021
Jan 1- June 30
8
1
3
0
2
1
0
0
0
0
0
0
0
1
2020
2019
5
5
4
3
1
1
2018
8
8
5
3
2
2
1
1
1
0
1
1
2017
3
4
4
3
1
2
2
1
3
2016
4
0
1
3
0
1
4
1
0
1
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
1
1
4
1
3
1
0
0
1
0
2
2
1
2
1
1
Customer Standard Due Diligence/Monitoring
AML Management
Suspicious Activity Monitoring
Compliance Monitoring and Oversight
Customer Enhanced Due Diligence/Monitoring
Systems and Controls
Record Keeping
Risk Management
Staff Training and Competency
Client Onboarding
Internal Audit
Sanctions Management
Supervision of Relevant Persons
Management Information
Staff Recruitment
Third-Party Oversight
IT Governance
98
142
101
60
38
40
33
30
24
17
9
5
13
7
5
5
2
*Rounded to the nearest million
*Rounded to the nearest million
Jan 1- June 30
Jan 1- June 30
U.S.
Jan 1- June 30
Jan 1- June 30
Jan 1- June 30
UK + EU
APAC
Global Total 2016-2021
Jan 1- June 30
APAC
Jan 1- June 30
Regulatory Reporting
34
1
2021
2020
2019
2018
2017
2016
Jan 1- June 30
Total Number of Failings 2016-2021
Total Number of Failings 2016-2021
Total Number of Failings 2016-2021
2021
2020
2019
2018
2017
2016
Total Number of Failings 2016-2021
2021
2020
2019
2018
2017
2016
Third-Party Oversight
IT Governance
0
0
0
0
0
0
0
0
0
0
0
0
Third-Party Oversight
IT Governance
Jan 1- June 30
2021
2020
$2,253.5 mn Total
$18.9 mn
Sanctions
$608 mn
Bribery
$1,626.6 mn
Money Laundering
2021
2021
$5.13 mn
Luxembourg
$917.15 mn
Australia
£0.01 mn
Germany
$3.80 mn
Hong Kong
$0.75 mn
Singapore
$1.41 mn
Italy
$578 mn
Netherlands
1
0
0
0
0
2
0
0
0
0
2
Jan 1- June 30
Jan 1- June 30
Jan 1- June 30
Number of fines issued
Jan 1- June 30
2021
2020
67 Total
8
Sanctions
4
Bribery
55
Money Laundering
2020
2019
2021
56 Total
5
Sanctions
6
Bribery
45
Money Laundering
2019
2018
2020
2021
61 Total
13
Sanctions
3
Bribery
45
Money Laundering
2018
2017
2019
2020
65 Total
7
Sanctions
6
Bribery
52
Money Laundering
2017
2016
2018
2019
64 Total
7
Sanctions
23
Bribery
34
Money Laundering
2016
2017
2018
69 Total
11
Sanctions
34
Bribery
24
Money Laundering
2021
2021
Jan 1- June 30
2021
2020
67 Total
8
Sanctions
4
Bribery
55
Money Laundering
Value of fines levied*
*Rounded to the nearest million
2020
2019
$4,675 mn Total
$27 mn
Sanctions
$2,427 mn
Bribery
$2,222 mn
Money Laundering
2019
2018
2020
$3,751 mn Total
$3,259 mn
Sanctions
$48 mn
Bribery
$444 mn
Money Laundering
2018
2017
2019
2020
$4,054 mn Total
$538 mn
Sanctions
$220 mn
Bribery
$3,297 mn
Money Laundering
2017
2016
2018
2019
$3,947 mn Total
$102 mn
Sanctions
$1,709 mn
Bribery
$2,136 mn
Money Laundering
2016
2017
2018
$8,417 mn Total
$31 mn
Sanctions
$7,497 mn
Bribery
$889 mn
Money Laundering
2021
2021
Jan 1- June 30
2021
2020
$2,253.5 mn Total
$18.9 mn
Sanctions
$608 mn
Bribery
$1,626.6 mn
Money Laundering
A HISTORY OF AML FINES GLOBALLY
2016
2017
2018
2019
2020
2021
Jan 1- June 30
24
34
52
45
45
55
*Rounded to the nearest million
$889 mn
$2,136 mn
$3,297 mn
$444 mn
$2,222 mn
$1,626.6 mn
Number of fines
Fine values*
$4.76 mn
United Kingdom
$19.32 mn
Singapore
$2.73 mn
France
$1.12 mn
Singapore
$2.59 mn
Hong Kong
$28.48 mn
Australia
$346.76 mn
France
$7.45 mn
Ireland
$204.22 mn
United Kingdom
$1,545 mn
U.S.
$1,909 mn
U.S.
$199.09 mn
U.S.
$328.91 mn
U.S.
$1.07 mn
Singapore
$356.9 mn
Hong Kong
$6.2 mn
Italy
$559.33 mn
Sweden
$0.21 mn
France
$47.45 mn
United Kingdom
$0.02 mn
Canada
$917.15 mn
Australia
$5.13 mn
Luxembourg
£0.01 mn Germany
$578 mn
Netherlands
$441.09 mn
United Kingdom
$1.23 mn
Luxembourg
$1.41 mn
Italy
$7.27 mn
France
$0.75 mn
Singapore
2021
Jan 1- June 30
7
5
6
4
5
1
2
3
2
2
2
2
2
1
0
0
0
0
14
3
12
9
3
1
4
6
4
4
2
2
0
1
1
0
0
0
24
9
19
14
6
6
7
3
4
3
1
2
1
1
0
1
0
0
5
3
3
1
2
8
1
1
1
0
0
0
1
1
0
0
0
0
10
11
2
1
2
1
0
1
0
1
0
0
0
0
0
0
0
0
12
5
6
1
1
3
3
1
0
1
0
0
0
4
0
0
0
0
Jan 1- June 30
27
72
57
31
18
19
18
15
11
10
6
6
4
8
1
1
0
0
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
Third-Party Oversight
IT Governance
Client Onboarding
Internal Audit
Sanctions Management
Supervision of Relevant Persons
Management Information
Staff Recruitment
2021
2020
2019
2018
2017
2016
Jan 1- June 30
Total Number of Failings 2016-2021
6
3
4
3
3
2
2
2
2
0
1
1
1
1
0
1
0
1
6
4
5
6
5
4
4
4
3
2
1
2
2
1
1
1
0
0
6
8
5
6
3
4
3
4
3
3
0
1
1
0
2
0
1
1
12
6
4
0
3
2
2
1
1
1
2
0
0
1
0
0
0
0
13
8
6
2
3
0
0
0
0
2
2
0
0
0
0
0
0
0
8
14
4
2
1
2
3
1
0
0
0
2
0
0
0
0
0
0
Jan 1- June 30
51
43
28
18
19
13
13
14
9
8
8
4
4
3
3
2
1
2
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
Third-Party Oversight
Client Onboarding
Supervision of Relevant Persons
2021
2020
2019
2018
2017
2016
Jan 1- June 30
Total Number of Failings 2016-2021
Management Information
3
4
4
3
1
2
2
1
3
0
0
0
0
0
8
8
5
3
2
2
1
1
1
0
1
1
0
0
5
5
4
1
3
1
1
0
1
0
0
0
0
1
1
4
1
3
1
0
0
1
0
2
2
1
1
2
8
1
3
0
2
1
0
0
0
0
0
0
0
1
4
0
1
3
0
1
4
1
0
1
0
0
0
0
Jan 1- June 30
27
20
16
11
7
7
7
4
3
4
3
2
2
3
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
Third-Party Oversight
IT Governance
Client Onboarding
Internal Audit
Sanctions Management
Supervision of Relevant Persons
Management Information
Staff Recruitment
98
142
101
60
38
40
34
33
30
24
17
9
5
13
7
5
5
2
2021
Although there has been an increase in the number
of fines, the total volume of fines is less. The overwhelming historical dominance of the U.S.
in AML-related fines now seems to be a thing of
the past, with the U.S. fines accounting for just
36% of the global total in 2021.
The latest data also highlights the four key AML failings from 2016-2021, which regulators across the world have consistently identified through the fines they imposed, including AML management, suspicious activity monitoring, customer due diligence, and compliance monitoring and oversight.
It is almost impossible to find a major global bank that has not been sanctioned for AML or other financial crime failing in recent years. This is reflective of the predominant focus global regulators have placed on ensuring AML measures
are functioning robustly at the world’s major financial services institutions. Now regulators are increasingly turning their enforcement attention to other financial services companies such as asset managers or cryptocurrency exchanges.
In a further shift of trends, 2021 also saw a new jurisdiction join the “top table”
of countries imposing major fines for AML failings—the Netherlands. Indeed,
in 2021, the Dutch regulator fined one of its major banks $578 million (mn), which alone represented 35% of the total value of AML fines globally.
Meanwhile, 2021 was another busy year for the UK, with AML failings accounting for over half the total value of UK fines issued by the Financial Conduct Authority (FCA) in 2021. In fact, 2021 saw AML fines as the
highest proportion of total fines by the FCA since 2017.
Kroll is a global advisor with extensive expertise
in a wide range of financial crime prevention areas. Our global team of financial crime specialists assists a wide range of regulated firms to improve their frameworks and arrangements to mitigate risks, meet regulatory requirements, and minimize reputational damage and enforcement action.
Enforcement penalties greater than $1 mn or equivalent across all selected regulators. For individuals, the $1 mn threshold does not apply.
All enforcement penalties (including those below $1 mn)
for financial services firms and associated individuals
with assets greater than $25 bn.
$0.24 mn
Belgium
$1.23 mn
Luxembourg
The latest data also highlights the four key AML failings from 2016-2021, which regulators across the world have consistently identified through the fines they imposed, including AML management, suspicious activity monitoring, customer due diligence, and compliance monitoring and oversight.
It is almost impossible to find a major global bank that has not been sanctioned for AML or other financial crime failing in recent years. This is reflective of the predominant focus global regulators have placed on ensuring AML measures are functioning robustly at the world’s major financial services institutions. Now regulators are increasingly turning their enforcement attention to other financial services companies such as asset managers or cryptocurrency exchanges.
$3.80 mn
Hong Kong
$0.24 mn
Belgium
