i-law

Money Laundering Bulletin

FATF pushes VASP regulation on rise in criminal use of virtual assets
The Financial Action Task Force (FATF) has called on governments to redouble efforts to boost their regulatory controls over virtual assets and currencies, given the increasing crime risks associated with these financial technologies.
Online Published Date:  26 June 2025
Appeared in issue:  326 - 01 September 2025
Compliance under fire: AML mid-conflict
War is the ultimate disruptor: protocols in opposing jurisdictions are changed, may be overridden, in the face of possible existential threat. The shifts and reversals pose challenges not only to the integrity of fund flows within states in dispute but to foreign financial institutions that deal with them and still need to meet compliance obligations. Mikhail Karataev articulates the particular risks and how they can be mitigated.
Online Published Date:  27 June 2025
Appeared in issue:  326 - 01 September 2025
BVI issues policy on beneficial owner data access if no objection upheld
Natural and legal persons with a "legitimate interest" will be able to access information on beneficial owners or those who otherwise exercise control, from a 25% threshold, of British Virgin Islands (BVI) business companies and limited partnership under new policy, published on 23 June.
Online Published Date:  28 June 2025
Appeared in issue:  326 - 01 September 2025
AMLA arrives: 1 July impact on EU financial crime supervision
The European Union's new Anti-Money Laundering Authority (AMLA) will begin operations on 1 July 2025. While the launch marks the end of years of legislative groundwork, says Enrico Aresu of Moody's, it also sets in motion a gradual shift in how financial crime supervision is approached across the EU, particularly for those firms under its direct remit, and potentially beyond.
Online Published Date:  01 July 2025
Appeared in issue:  326 - 01 September 2025
Ink to action - Cape Verde
The African archipelago state Cape Verde may be legislating to strengthen its anti-money laundering regime but improvement will depend as much on resourcing and enforcement, finds Andreia Nogueira.
Online Published Date:  02 July 2025
Appeared in issue:  326 - 01 September 2025
Nine financial institutions fined S$27.5m in Singapore for AML failings
In fallout from a major money laundering case, in 2023, involving gold bars and luxury cars linked to online gambling, which led to the conviction of 10 Chinese nationals in Singapore, nine firms in the country, including Credit Suisse, UBS and Citibank, have been issued penalties totalling S$27.45m (US$21.54m).
Online Published Date:  04 July 2025
Appeared in issue:  326 - 01 September 2025
Isle of Man fines two gambling operators over broad AML failings
Online gambling firms Celton Manx and SK IOM Limited have incurred civil penalties of UK£3,937,500 (US$ 5,376,850) and UK£70,000 (US$95,590), respectively, for anti-money laundering and counter financing of terrorism (AML/CFT) compliance breaches uncovered by the Isle of Man (IoM) Gambling Supervision Commission during inspections in 2024.
Online Published Date:  05 July 2025
Appeared in issue:  326 - 01 September 2025
UAE fines foreign bank and exchanges houses for AML/CFT breaches
Four exchange houses (unnamed) have been fined by the Central Bank of the United Arab Emirates (CBUAE) - three, a total of D4,100,000 (US$1,116,250), on 7 July and one, D2,000,000 (US$544,510), on 24 June - for non-compliance with local anti-money laundering/counter financing of terrorism obligations.
Online Published Date:  07 July 2025
Appeared in issue:  326 - 01 September 2025
FATF tracks terrorist financing shift to informality, younger recruits, more links to organised crime
The Financial Action Task Force (FATF) has warned how the financing of terrorism (TF) has become less formal and more decentralised, with violent activists increasingly young and focused on remote and marginalised communities, such as in the Sahel.
Online Published Date:  08 July 2025
Appeared in issue:  326 - 01 September 2025
Monzo fined UK£21m for flawed CDD; new high-risk customer accounts breached undertaking
UK fintech, latterly challenger bank Monzo has been ordered to pay a UK£21,091,300 (US$28,638,175) by the Financial Conduct Authority (FCA) over inadequacies in its customer onboarding, which enabled some accounts to be registered to addresses of "well-known London landmarks", including Buckingham Palace and 10 Downing Street, and for contravening a restriction barring it from taking on high-risk customers.
Online Published Date:  09 July 2025
Appeared in issue:  326 - 01 September 2025
Under full sail - Mauritius
Very few jurisdictions can claim almost total technical compliance with the Financial Action Task Force 40 Recommendations: Mauritius is one, but, like the rest, it has a way to go in improving effectiveness of its anti-money laundering regime, with recent structural changes unproven. Villen Anganan, in Beau-Bassin, Mauritius, & Keith Nuthall trace through the multitude of legal and institutional reforms.
Online Published Date:  10 July 2025
Appeared in issue:  326 - 01 September 2025
Wise fined US$4.2m over reporting and data integrity failings
Wise US, Inc, a subsidiary of UK-listed Wise Plc, the global money transfer business, has been fined US$4.2 million, in total, by the New York Department of Financial Services and five other state regulators for violations of Bank Secrecy Act/Anti-Money Laundering and Counter Financing of Terrorism obligations.
Online Published Date:  10 July 2025
Appeared in issue:  326 - 01 September 2025
Canaccord Genuity pays Can$544,500 for reporting, CDD, risk assessment breaches
Securities dealer Canaccord Genuity Corp. has been ordered to pay Can$544,500 (US$397,465) after FINTRAC, the Canadian financial intelligence unit, found it had committed four violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act during a 2023 examination.
Online Published Date:  11 July 2025
Appeared in issue:  326 - 01 September 2025
Barclays fined UK£39.3m over repeated failure to act on ML signals
UK high street lender Barclays Bank Plc has been ordered by the UK Financial Conduct Authority to pay UK£39,314,700 (US$52,690,075) over persistent lack of response to warnings of money laundering risk attaching to its business customer Stunt & Co Ltd, between 9 January 2015 and 23 April 2021.
Online Published Date:  16 July 2025
Appeared in issue:  326 - 01 September 2025
Interactive Brokers pays US$11.8m for multiple breaches of US sanctions
Electronic broker-dealer Interactive Brokers LLC has settled with the US Office of Foreign Assets Control (OFAC), paying US$11,832,136, for "apparent violations" of various US sanctions programmes between 15 July 2016 and 31 January 2024. The failings, though extensive, were deemed non-egregious, and self-disclosed.
Online Published Date:  16 July 2025
Appeared in issue:  326 - 01 September 2025
Barclays fined UK£3m over weak CDD on wealth manager's client account
Inadequate customer due diligence (CDD) on a business customer and its client account have cost Barclays Bank UK PLC a UK£3,093,600 (US$4,155,570) penalty from the UK Financial Conduct Authority.
Online Published Date:  16 July 2025
Appeared in issue:  326 - 01 September 2025
Mexico fines US-sanctioned banks and broker for compliance breaches
CIBanco, Intercam Banco and brokerage firm Vector Casa de Bolsa have been fined 185 million pesos (US$9.8 million), in total, by Mexico's National Banking and Securities Commission (CNBV) for compliance breaches, in the wake of US FinCEN accusations that they have "collectively played a longstanding and vital role in laundering millions of dollars on behalf of Mexico-based cartels and facilitating payments for the procurement of precursor chemicals needed to produce fentanyl".
Online Published Date:  19 July 2025
Appeared in issue:  326 - 01 September 2025
Casino, crypto and fintech ML risks on the rise - UK NRA
The risks that UK-based casinos, cryptoasset businesses and fintechs could be involved in money laundering have risen between 2020 and 2025, the latest UK National Risk assessment of Money Laundering and Terrorist Financing (NRA) concludes.
Online Published Date:  19 July 2025
Appeared in issue:  326 - 01 September 2025
US delays and reopens investment adviser rule
FinCEN, the US financial intelligence unit, announced on 21 July that it would revisit the final rule requiring certain investment advisers to implement anti-money laundering and counter terrorist financing controls and file suspicious activity reports.
Online Published Date:  22 July 2025
Appeared in issue:  326 - 01 September 2025
Three banks fined in Hong Kong for AML breaches
Local branches of Indian Overseas Bank (IOBHK) and Bank of Communications Co. Ltd. (BCOM Hong Kong Branch) have been fined, respectively, HK$8.5 million (US$1.1 million) and HK$3.7 million (US$0.5 million), by the Hong Kong Monetary Authority (HKMA) for breaches of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO). HKMA, the same day, 22 July 2025, levied a third penalty, of HK$4 million (US$0.5 million), on Bank of Communications (Hong Kong) Limited (BCOM(HK)), also for failings under the AMLO.
Online Published Date:  23 July 2025
Appeared in issue:  326 - 01 September 2025
UK law firm fines keep AML on risk radar
Financial penalties on eight UK firms of solicitors in July point to continuing focus by the Solicitors Regulation Authority (SRA) on compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulation 2017.
Online Published Date:  25 July 2025
Appeared in issue:  326 - 01 September 2025
ITI Trade and director fined in Guernsey over wide-ranging AML risk and compliance failings
Execution-only and prime brokerage ITI Trade Ltd (ITIT), now in administration, must pay a UK£175,000 (US$235,130) financial penalty, and its former director, Alex Phil (originally 'Filatov'), UK£35,000 (US$47,025) to the Guernsey Financial Services Commission (GFSC) for effectively running a front operation whose real business was conducted largely through a sister company in Russia, where customer due diligence (CDD) and sanctions screening did not meet the Bailiwick's standard.
Online Published Date:  26 July 2025
Appeared in issue:  326 - 01 September 2025
Fintechs expanding, often not equipped for ML/TF risk - EBA Opinion
While fintech firms take a growing share of the financial services market, 70% of competent authorities in EU member states find their ML/TF risk exposure is high or rising, according to the European Banking Authority (EBA).
Online Published Date:  29 July 2025
Appeared in issue:  326 - 01 September 2025
Aftermath - AML post-conflict
All wars end - eventually; at least, the guns fall silent - the criminals merely change strategy, opening new fronts to plunder aid and reconstruction funds. Financial institutions focus heavily on sources of money in anti-money laundering but, in transitioning to peace, Mikhail Karataev argues they must direct more attention to monitoring where it goes.
Online Published Date:  30 July 2025
Appeared in issue:  326 - 01 September 2025
Understand and tackle terrorist financing risk - the FATF guide reworked
The ordering anti-money laundering/counter terrorist financing (AML/CTF) is telling, but while the probability of processing funds linked to a terrorist attack may well be lower by far than for laundering funds derived from 'ordinary' crime, the impact can be incalculably greater - deadly - so a risk-based approach demands, if different, no lesser attention to the TF threat. Jonah Anderson and Phil Taylor of White & Case find useful assessment and instruction in a wholly updated and revised publication from the Financial Action Task Force.
Online Published Date:  31 July 2025
Appeared in issue:  326 - 01 September 2025
UK solicitors hit with fines over missing risk assessments
Amphlett Lissimore Bagshaws LLP, of London, and Andrew & Andrew Solicitors Limited, based in Portsmouth, will pay penalties of UK£114,006 (US$150,472) and UK£25,000 (US$33,000), respectively, after desk-based reviews by the Solicitors Regulation Authority (SRA) found breaches of the Money Laundering Regulations 2017.
Online Published Date:  31 July 2025
Appeared in issue:  326 - 01 September 2025
Markom Management fined £300,000 in UK over Crimea sanctions breach
A UK-registered company services provider that instructed payment, in 2018, to a designated person under The Ukraine (European Union Financial Sanctions) (No. 2) Regulations 2014, has been fined UK£300,000 (US$394,985) by the UK Office of Financial Sanctions Implementation (OFSI).
Online Published Date:  01 August 2025
Appeared in issue:  326 - 01 September 2025
Spuerkeess pays €5m in Luxembourg for monitoring and CDD failings
The Banque et Caisse d'Épargne de l'État, or Spuerkeess, was fined €4,968,780 (US$5,746,780) on 2 May in Luxembourg for compliance failings in transaction monitoring and customer due diligence.
Online Published Date:  01 August 2025
Appeared in issue:  326 - 01 September 2025
Law firms fined over CDD failings in S$3 billion Singapore laundering case
Six law firms and lawyers who work, or did so, for some of them have been penalised by Singapore's Ministry of Law for their role in the country's largest money laundering case, in 2023, involving around S$3 billion (US$2.2 billion) in criminal funds derived from online scams and gambling, some of which was invested in luxury real estate.
Online Published Date:  05 August 2025
Appeared in issue:  326 - 01 September 2025
UK lawyer struck off for "widespread and fundamental" AML non-compliance
A sole practitioner, who admitted dishonesty in confirming to the Solicitors Regulation Authority for England & Wales that he had a firm-wide risk assessment (FWRA) for money laundering and terrorist financing when he did not, has lost his licence.
Online Published Date:  06 August 2025
Appeared in issue:  326 - 01 September 2025
Speed kills - challenger banks' approach to risk
At a very basic level, there are two aspects to risk calculus - there's the chance of being caught and then the consequences; if both are rated low, risk-taking is set fair.
Online Published Date:  08 August 2025
Appeared in issue:  326 - 01 September 2025
In retrograde? - USA AML
President Trump's radicalism knows no bounds, it would seem - financial crime control has not escaped, certainly: setting aside convictions; suspending Foreign Corrupt Practices Act casework; hollowing out the Anti-Money Laundering Act, halting long-anticipated implementation of a beneficial ownership register and pausing extension of AML requirements to investment advisers, and that's before any doubts that might be raised about the administration's stance on cryptocurrency - what does it all mean for anti-money laundering professionals? Keith Nuthall takes stock and seeks counsel.
Online Published Date:  08 August 2025
Appeared in issue:  326 - 01 September 2025
Paxos pays US$26.5m in New York for Binance AML not checked and wider CDD, monitoring defects
The first company to be granted a charter in New York to offer cryptocurrency services has been fined US$26.5 million for anti-money laundering compliance failings, notably in its dealings with Binance, the world's leading digital currency exchange.
Online Published Date:  09 August 2025
Appeared in issue:  326 - 01 September 2025
Niger - military advance
Democracy may not be the order in Niger today but the army leadership is responding to the threat that criminal and, especially, terrorist financing present to any prospects for a stable peace and development, find Dan Jarida, reporting from the capital, Niamey, and Keith Nuthall.
Online Published Date:  11 August 2025
Appeared in issue:  326 - 01 September 2025
Revise and finalise: UK Money Laundering Regulations and FCA PEP guidance
July 2025 saw various UK anti-money laundering updates, reflecting the Government's stated commitment to ensure that compliance obligations are effective yet not unnecessarily onerous. Recent revisions focus on making customer due diligence and enhanced due diligence requirements more practical and proportionate. Eve Ellis, Dorota Maj and Imogen Galilee of Ropes & Gray provide an overview of two sets of changes and their implications.
Online Published Date:  11 August 2025
Appeared in issue:  326 - 01 September 2025
Law reforms, enforcement lags - Canada
A major overhaul and expansion of anti-money laundering legislation should help Canada's technical compliance scores when the Financial Action Task Force comes calling, possibly in November this year, but Keith Nuthall, in Ottawa, looks as well at prospects for increased police resourcing and momentum to boost convictions.
Online Published Date:  12 August 2025
Appeared in issue:  326 - 01 September 2025
EU AML/CFT SupTech not there yet, finds EBA
The new model of anti-money laundering supervision in the European Union (EU), which seeks greater consistency of approach and coordination under AMLA - the Anti-Money Laundering and Countering the Financing of Terrorism Authority - will rely heavily on IT innovation and data compatibility, but AML/CFT supervisory technology (SupTech) in national competent authorities is still "at an early stage", according to the European Banking Authority (EBA).
Online Published Date:  13 August 2025
Appeared in issue:  326 - 01 September 2025
Over half of fraud payments in money mule account less than an hour - RUSI study
Analysis of Lloyds Banking Group data on transfers from known money mule accounts from mid-June to mid-August last year, by researchers at the Royal United Services Institute (RUSI), found that just under 28% of the total value left within 15 minutes, and another 25% within an hour. Under 15% stayed in the mule account beyond 24 hours.
Online Published Date:  14 August 2025
Appeared in issue:  326 - 01 September 2025

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