AML Case studies

This page aims to provide a list of AML recent fines issued by different financial authorities (mainly UK & US based). The fines can be used as case studies for understanding potential shortcomings in implementing AML adequate policies and procedures, and for improving these accordingly.

I have categorised cases according to financial authorities’ fines.

Financial Conduct Authority – FCA – UK


Standard Bank PLC - The Financial Conduct Authority (FCA) has fined Standard Bank PLC (Standard Bank)£7,640,400 for failings relating to its anti-money laundering (AML) policies and procedures over corporate customers connected to politically exposed persons (PEPs). (23/01/2014)


JLT Specialty Limited - The FCA has fined JLT Specialty Limited (JLTSL) over £1.8million for failing to have in place appropriate checks and controls to guard against the risk of bribery or corruption when making payments to overseas third parties. (19/12/2013)

Guaranty Trust Bank (UK) Limited - The FCA fined Guaranty Trust Bank (UK) Limited £ 525,000 for failings in its anti-money laundering (AML) controls for high risk customers. (08/08/2013)

EFG Private Bank - The FCA fined EFG Private Bank £ 4,2million for failing to take reasonable care to establish and maintain effective anti-money laundering (AML) controls for high risk customers. (28/03/2013)

Financial Industry Regulatory Authority – FINRA – US


Wedbush Securities  – FINRA fined Wedbush Securities for different reasons including AML deficiencies. In particular,  the firm failed to establish, maintain and enforce adequate AML policies and procedures, and failed to report suspicious and potentially manipulative transactions. (18/08/2014)

Brown Brothers Harriman - FINRA fined Brown Brothers Harriman a Record $8 Million for Substantial Anti-Money Laundering Compliance Failures. Highest Fine Levied by FINRA for AML-Related Violations; Former AML Compliance Officer Also Fined and Suspended. (05/02/2014)

Banorte-Ixe Securities - FINRA fined Banorte-Ixe Securities $475,000 for Inadequate Anti-Money Laundering Program and for Failing to Register Foreign Finders. Firm Failed to Monitor, Detect and Report $28 Million Activity in Customer Account Reportedly Tied to Mexican Drug Cartel. (28/01/2014)


COR Clearing LLC – FINRA fined COR Clearing LLC (formerly Legent Clearing LLC), of Omaha, Nebraska, $1 million for numerousfailures to comply with anti-money laundering (AML), financial reporting and supervisory obligations. (16/12/2013)

Oppenheimer & Co., Inc - FINRA fined Oppenheimer & Co., Inc. $1.4 Million for Sale of Unregistered Penny Stocks and Anti-Money Laundering Violations. (05/08/2013)

Atlas One Financial Group, LLC Action; Firstrade Securities, Inc. Action; World Trade Financial Corporation Action - FINRA fined three firms a total of $900,000 for failing to establish and implement adequate anti-money laundering (AML) programs and other supervisory systems to detect suspicious transactions. FINRA also fined and suspended four executives involve(08/05/2013)