Insight

Insight

We look beyond today

  • Beyond False Positives: Risk-Based AML in the Age of AI
    Compliance is broken. False positives overwhelm teams, innovation outpaces controls, and firms are still punished for frameworks that look good on paper but fail in practice. Beyond False Positives is a definitive guide for leaders who refuse to choose between growth and compliance. If you’re curious, it’s available here: https://amzn.eu/d/63ZNq4b
  • Credit Suisse Indictment Highlights Swiss AML Failures in Mozambique Debt Scandal
    On 1 December 2025, Swiss federal prosecutors filed a high-profile indictment connected to the controversial “Mozambique Debt Scandal.” Authorities charged a former Credit Suisse compliance officer with money laundering offences and accused the bank — now part of UBS after the 2023 takeover — of organisational shortcomings that failed to prevent suspicious fund transfers. The case revolves around loans exceeding $2?billion that Credit Suisse arranged in 2013 for three state-owned Mozambican companies, ostensibly to support development of the country’s tuna fishing industry. A portion of the proceeds — including $7.9?million transferred from Mozambique’s Ministry of Economy and Finance to a… Read more: Credit Suisse Indictment Highlights Swiss AML Failures in Mozambique Debt Scandal
  • JPMorgan Hit with Record €45 Million AML Fine in Germany
    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… Read more: JPMorgan Hit with Record €45 Million AML Fine in Germany
  • U.S. Regulators Issue Clarifications on Suspicious Activity Reporting
    The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), in collaboration with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency, issued answers to frequently asked questions (FAQs) to clarify certain requirements related to suspicious activity reports (SARs). The FAQs aim to assist financial institutions covered by SAR rules in understanding and complying with regulatory requirements related to SARs and other anti-money laundering/countering the financing of terrorism (AML/CFT) considerations. These clarifications are part of ongoing efforts by U.S. regulators… Read more: U.S. Regulators Issue Clarifications on Suspicious Activity Reporting
  • FINTRAC Fines First Nations Bank of Canada for AML Non-Compliance
    First Nations Bank of Canada (FNBC), headquartered in Saskatoon, Saskatchewan, was fined CAD 601,139.80 for multiple violations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. The violations included: FINTRAC emphasized the importance of compliance to protect the safety and security of Canada’s financial system and stated that administrative monetary penalties aim to encourage businesses to rectify non-compliant behaviour.
  • FINTRAC fines British Columbia Lottery Corporation for AML violations
    Canada’s FINTRAC (Financial Transactions and Reports Analysis Centre of Canada) imposed an administrative monetary penalty on British Columbia Lottery Corporation (BCLC) for non-compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations. The penalty amounts to CAD 1,075,000 and relates to violations identified during a compliance examination. The findings included:
  • HKMA disciplines three banks over AML control failures
    The Hong Kong Monetary Authority (HKMA) took disciplinary actions against three banks — Indian Overseas Bank (Hong Kong Branch), Bank of Communications (Hong Kong), and Bank of Communications (Hong Kong Branch) — for violations of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO).
  • Barclays Fined £42 Million for AML Control Failures
    The FCA fined Barclays £42 million for failing to assess money laundering risks while providing services to clients Stunt & Co and WealthTek. Barclays did not gather sufficient information at the start of the relationship or carry out proper ongoing monitoring for these clients, despite receiving information from law enforcement about potential money laundering activities. The FCA emphasised the importance of robust financial crime controls and adequate due diligence in preventing the facilitation of financial crime.
  • Monzo Bank Fined £21 Million for AML Failings
    The UK’s Financial Conduct Authority (FCA) fined Monzo Bank £21.1 million for inadequate anti-money laundering (AML) systems and controls between October 2018 and August 2020. Monzo onboarded over 34,000 high-risk customers between August 2020 and June 2022, breaching a restriction imposed by the FCA. The FCA highlighted that Monzo accepted customers with implausible information, such as using well-known London landmarks as addresses, indicating significant lapses in customer due diligence.
  • Switzerland fines Pictet for AML lapses; ex-manager sentenced
    Key details: The Swiss Attorney General’s Office handed a former wealth manager at Pictet Bank a six-month suspended prison sentence for involvement in a money laundering scheme.

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