Over the past couple of years, regulators globally have ramped up enforcement. Several recurring patterns are emerging in the fines being levied — especially around weak onboarding, poor oversight of high-risk jurisdictions, and failure to identify beneficial ownership properly. Understanding these helps compliance teams stay ahead.

Consequences Seen in Recent Cases

• Substantial fines: The amounts are growing, especially for larger institutions with legacy problems. Example: TD Bank faced new enforcement for letting high-risk transactions go unchecked over several years.
• Enforcement of remediation: Regulators not only fine but require remediation plans, audits, change of systems, stronger oversight and sometimes external monitors.
• Reputational impact: These failures tend to hit public trust; news coverage, investigations, and media attention follow. Even if financials absorb the cost, brand damage tends to last.

Lessons & What Compliance Teams Should Prioritize

• Onboarding needs full due diligence: collect proof of identity, source of funds, business purpose, and UBO upfront, with risk-based checks for high-risk clients.
• Enhanced screening for high-risk jurisdictions: apply stricter due diligence and monitoring for countries under sanctions, high corruption, or FATF grey/black lists.
• Beneficial ownership verification is not optional: use reliable data sources, refresh ownership details regularly, and flag any changes in control structures.
• Ongoing monitoring & periodic reviews: continuously track transactions and reclassify clients when risks evolve due to adverse media or geopolitical shifts.
• Strong governance, documentation & escalation: maintain clear records, empower teams to escalate red flags, and run internal audits to catch gaps early.

Newsletter Takeaway

Regulators are no longer tolerating legacy failures hidden under “past system” excuses. The trend is clear: weak onboarding, blind spots around high-risk jurisdictions, and opaque ownership are among the top triggers for large AML fines. If your compliance program is to stay resilient, addressing these isn’t optional — it’s foundational.