2024 was a notable year for financial crime, marked by heightened scrutiny on compliance and major enforcement actions for anti-money laundering (AML) and countering the financing of terrorism (CFT) regulation shortcomings.
In this article, we examine some of the largest AML/CFT fines imposed throughout the year, spotlighting the companies involved, the regulatory issues they faced, and the broader implications these penalties had on their respective industries.
This list draws on research conducted by Pietro Odorisio, an AML/CFT expert based in Switzerland, complemented by further desk research.
The Largest AML/CFT Fines of 2024
TD Bank (US) – US$3.1 billion
In October, TD Bank became the largest bank in US history to plead guilty to violating a federal law aimed at preventing money laundering, agreeing to pay over US$3.1 billion in penalties to resolve the charges. The fine is one of the biggest financial penalties ever paid by a financial institution.
Prosecutors said the bank operated with inadequate guards against money laundering for nearly a decade, failing to act even when staff flagged obvious cases of abuse, such as a customer making daily deposits of US$1 million in cash, the BBC reported.
By 2018, TD Bank had failed to monitor over 90% of its US$18 trillion transaction network. These failures allowed widespread criminal activity, including laundering US$470 million in drug proceeds and facilitating US$39 million in illicit transfers to Colombia.
The penalties, including US$1.8 billion in criminal fines and US$1.3 billion in civil penalties, also impose growth restrictions and require independent monitoring.
TD Bank is the sixth largest bank in North America by assets and serves over 27.5 million customers around the world.
Wynn Las Vegas (US) – US$130 million
In September, US casino company Wynn Las Vegas (WLV) agreed to pay US$130 million to federal authorities, admitting that it let unlicensed money transfer businesses around the world transfer funds to gamblers at its flagship Las Vegas Strip property.
According to the US Department of Justice (DOJ), the publicly traded company contracted with third-party independent agents that transferred foreign gamblers’ funds through “companies, bank accounts, and other third-party nominees in Latin America and elsewhere, and ultimately into a WLV-controlled bank account.”
The money was then transferred into a WLV cage account, which employees credited to the WLV account of each individual patron, enabling these gamblers to allegedly “evade foreign and US laws governing monetary transfer and reporting.”
In other instances, WLV allegedly knowingly failed to report suspicious activity or scrutinize the source of funds.
This case highlights the growing scrutiny of financial compliance in the casino and gambling industry.
City National Bank (US) – US$65 million
In January, the US Office of the Comptroller of the Currency (OCC) imposed a US$65 million civil money penalty on City National Bank (CNB), based in Los Angeles, California. The fine relates to systemic deficiencies in the bank’s risk management and internal controls.
The OCC found that the bank engaged in unsafe or unsound practices, including its failure to establish effective risk management and internal controls. This failure also resulted in non-compliance with regulatory guidelines. These failures contributed to significant weaknesses in the bank’s AML program and fiduciary activities oversight.
The penalty was accompanied by a cease-and-desist order requiring the bank to take broad and comprehensive corrective actions to improve its strategic plan, operational risk management, including internal controls; compliance risk management, including the Bank Secrecy Act/AML and fair lending; strategic risk management; and investment management practices.
Klarna Bank (Sweden) – US$44.8 million
In December 2024, Sweden’s financial supervisory authority, Finansinspektionen, issued Klarna Bank a remark and an administrative fine of SEK 500 million (US$44.8 million) for violating AML regulations.
The investigation, which covered the period from April 2021 to March 2022, found significant deficiencies in Klarna’s compliance with key AML requirements, especially in regards to its general risk assessment and customer due diligence procedures.
In addition, Klarna Bank didn’t have procedures and guidelines in place that capture all situations for when due diligence measures should be taken for customers that use the firm’s invoice product.
The authority said that while the violations weren’t severe enough to warrant a warning or withdrawal of authorization, the fine highlights Klarna Bank’s failure to meet AML standards and the risks posed by non-compliant.
SkyCity Adelaide (Australia) – US$41.5 million (AUD 67 million)
In June, the Australian Federal Court ordered SkyCity Adelaide to pay a AUD 67 million (US$41.5 million) penalty for its breaches of the AML/CFT Act.
SkyCity Adelaide admitted to operating in contravention of the AML/CFT Act over many years, a breach which allowed high-risk customers to move millions of dollars through the casino, hiding the source and ownership of these funds.
The fine represents the second order of significant civil penalties against an Australian casino after the Federal Court in 2023 ordered Crown Melbourne and Crown Perth to pay a A$450 million (US$280 million) fine over two years for breaches of the AML/CFT Act.
Starling Bank (UK) – US$35.4 million (GBP 29 million)
In October 2024, the UK Financial Conduction Authority (FCA) fined Starling Bank nearly GBP 29 million (US$35.4 million) for financial crime failings related to its financial sanctions screening and the opening of accounts for high-risk customers.
Starling Bank grew quickly, from approximately 43,000 customers in 2017 to 3.6 million in 2023. However, measures to tackle financial crime did not keep pace with its growth, the authority said.
When the FCA reviewed financial crime controls at challenger banks in 2021, it identified serious concerns with the AML and sanctions framework in place at Starling Bank. Though the bank agreed to a requirement restricting it from opening new accounts for high-risk customers until this improved, it failed to comply and opened over 54,000 accounts for 49,000 high-risk customers between September 2021 and November 2023.
Nordea (US) – US$35 million
In August, 2024, Nordea reached a final resolution with the New York State Department of Financial Services (DFS) following an investigation related to the adequacy of Nordea’s AML program during the period 2008 to 2019. Under the resolution with DFS, Nordea agreed to accept a fine totaling US$35 million.
The DFS investigated Nordea after the 2016 Panama Papers leak exposed the bank’s alleged role in helping customers create offshore tax-sheltered companies and entities connected to money laundering operations.
The authority found that Nordea failed to maintain an effective and compliant AML program, failed to conduct adequate due diligence in its correspondent bank relationships, and failed to maintain an adequate transaction monitoring system.
Metro Bank (UK) – GBP 16.7 million (US$20.4 million)
In November, the UK FCA fined Metro Bank GBP 16.7 million (US$20.4 million) for failing to have the right systems and controls to adequately monitor over 60 million transactions, with a value of over GBP 51 billion, for money laundering risks.
Metro Bank automated the monitoring of customer transactions for potential financial crime in June 2016. However, its system did not work as intended. An error in how data was fed into the system meant transactions taking place on the same day an account was opened, and any further transactions until the account record was updated, were not monitored.
Junior staff did raise concerns about some transaction data not being monitored in 2017 and 2018, but these did not result in the issue being identified and fixed. Even once a fix had been put in place in July 2019, Metro Bank did not have a mechanism to consistently check that all relevant transactions were being fed into the monitoring system until December 2020, over four and a half years after the system was implemented.
LPL Financial (US) – US$18 million
LPL Financial said in October that it had set aside US$18 million during Q3 in preparation for a settlement with the US Securities and Exchange Commission (SEC) over AML violations.
This penalty reflects a civil monetary penalty proposed by the SEC as part of a settlement to resolve a civil investigation into certain elements of the company’s AML compliance program.
This comes after the independent brokerage giant agreed to pay US$50 million in August 2024 as part of a separate settlement related to compliance failures in keeping records of financial advisors’ and employees’ electronic communications, such as text messages and apps.
N26 (Germany) – EUR 9.2 million (US$9.5 million)
In May, the German Federal Financial Supervisory Authority (BaFin) imposed a fine of EUR 9.2 million (US$9.5 million) on digital bank N26 Bank over shortcomings in reporting suspicious activity in 2022.
Credit institutions are obliged to submit a report to the Financial Intelligence Unit if they suspect that a transaction could be related to money laundering or terrorist financing. However, N26 Bank failed to forward its reports within the stipulated time.
In response to the penalty, N26 Bank said it has implemented numerous measures to improve reporting processes from 2022 onwards. The bank has also invested over EUR 80 million in personnel and technical infrastructure to maintain industry standards in combating financial crime and money laundering.
Featured image credit: edited from freepik