On 6 November 2025, Germany’s financial watchdog BaFin imposed a record €45?million fine on the Frankfurt branch of U.S. banking giant JPMorgan Chase, citing serious deficiencies in its anti?money?laundering (AML) controls. Under Germany’s Anti?Money Laundering Act (Geldwäschegesetz), financial institutions are legally required to submit Suspicious Activity Reports (SARs) immediately when they detect transactions that could involve money laundering or terrorist financing.
BaFin found that JPMorgan SE “systematically failed” to file these reports without undue delay over a one?year period — from October 2021 to September 2022. The regulator described this as a breach of the bank’s supervisory duties, highlighting lapses in internal AML procedures and controls.
While the delays did not appear to hinder law enforcement investigations, BaFin stressed that they still represented a serious failure to meet regulatory obligations designed to safeguard the financial system. JPMorgan acknowledged these historical shortcomings and reaffirmed its commitment to combating money laundering and financial crime.
This enforcement action represents BaFin’s largest fine ever for AML failings, surpassing previous penalties and reinforcing Germany’s tough stance on AML compliance, particularly for large international banks.
Key AML takeaways:
- Timely SAR filing is essential to effective AML enforcement.
- Fines reflect both the severity of the breach and the size of the institution.
- AML enforcement increasingly targets systemic procedural weaknesses, not just individual compliance gaps.