2024 has seen significant penalties against financial institutions for failures in anti-money laundering (AML) and countering the financing of terrorism (CFT). These regulatory fines have sparked attention across the financial sector, serving as stark reminders of the importance of robust compliance programs. As scrutiny on financial crime intensifies, companies are facing greater consequences for lapses in their AML/CFT practices. This article explores some of the largest fines of 2024, detailing the companies involved, the reasons for their penalties, and the broader impact on their industries.
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TD Bank: A Historic $3.1 Billion Penalty
TD Bank, headquartered in the US, made history in October 2024 by becoming the largest financial institution in the US to plead guilty to violating federal anti-money laundering laws. The bank agreed to pay a staggering US$3.1 billion in fines, one of the largest penalties ever imposed on a financial institution. The fine was a result of TD Bank’s inadequate controls to prevent money laundering over a span of nearly a decade.
Prosecutors revealed that the bank failed to act on clear warning signs, such as a customer depositing US$1 million in cash daily. Even when these red flags were flagged by bank staff, the proper checks were not enforced. By 2018, TD Bank had failed to monitor over 90% of its US$18 trillion transaction network. This oversight allowed illegal transactions, including US$470 million in drug proceeds and US$39 million transferred to Colombia.
The fine, divided into US$1.8 billion in criminal penalties and US$1.3 billion in civil penalties, came with strict regulatory consequences, including growth restrictions and a requirement for independent monitoring.
Wynn Las Vegas: $130 Million for Unlicensed Transfers
In a high-profile case involving the gambling sector, Wynn Las Vegas was fined US$130 million in September 2024 for facilitating illicit money transfers. The US Department of Justice (DOJ) revealed that the casino allowed unlicensed money transfer businesses to funnel funds into the US for gambling purposes. This was done through third-party agents, bypassing both US and foreign monetary transfer laws.
Wynn Las Vegas failed to monitor and report suspicious transactions, and in some cases, the funds were transferred directly into the casino’s accounts for the gamblers. The case highlights the growing pressure on casinos to maintain robust AML/CFT practices, as these establishments are increasingly scrutinized for financial crime compliance.
City National Bank: $65 Million Penalty for Weak Internal Controls
City National Bank, based in Los Angeles, received a US$65 million civil penalty in January 2024 due to severe deficiencies in its AML program. The bank was found to have systemic weaknesses in its internal controls and risk management practices. These failures led to non-compliance with regulatory guidelines, including the Bank Secrecy Act (BSA).
The US Office of the Comptroller of the Currency (OCC) discovered that the bank had failed to establish an effective AML program. The lack of proper due diligence processes meant that City National Bank did not monitor high-risk transactions adequately, which posed significant risks for money laundering activities. The bank has since been required to undertake extensive corrective actions, including enhancing its risk management framework and improving its AML controls.
Klarna Bank: A SEK 500 Million Fine for Non-Compliance
Klarna Bank, a leading Swedish financial institution, was fined SEK 500 million (US$44.8 million) by Sweden’s Finansinspektionen in December 2024. The fine was a result of significant deficiencies in Klarna’s AML compliance, particularly in customer due diligence and risk assessment procedures. The investigation revealed that Klarna had failed to implement adequate processes to identify and manage risks for customers using its invoice product.
Despite not being severe enough to result in the withdrawal of its license, the fine underscores the importance of adhering to AML regulations. Klarna Bank’s failure to meet the required AML standards poses potential risks not only to the institution but also to the financial system.
SkyCity Adelaide: AUD 67 Million for AML Breaches
SkyCity Adelaide, an Australian casino, faced a penalty of AUD 67 million (US$41.5 million) in June 2024 after admitting to multiple breaches of the Australian AML/CFT Act. The Australian Federal Court found that the casino allowed high-risk customers to move large sums of money without properly identifying the source or ownership of these funds. This case highlights the growing scrutiny of AML practices in the gambling sector, where illicit financial activities are increasingly coming under the spotlight.
The case is part of a larger trend, as Australian regulators continue to crack down on financial crime in casinos. SkyCity’s penalty follows a similar fine imposed on Crown Melbourne and Crown Perth, both of which were penalized for their failure to prevent money laundering activities in 2023.
Starling Bank: £29 Million for Sanctions Failures
In October 2024, UK-based Starling Bank was fined GBP 29 million (US$35.4 million) by the UK Financial Conduct Authority (FCA) for failing to comply with financial crime regulations. The bank’s rapid growth, from 43,000 customers in 2017 to over 3.6 million in 2023, did not correspond with the enhancement of its AML framework. This led to multiple failures, including opening accounts for high-risk customers without proper screening.
The FCA found that Starling had failed to implement sufficient measures to prevent financial crime, which led to the opening of over 54,000 accounts for high-risk customers. The fine serves as a reminder of the challenges that rapidly growing financial institutions face in keeping their compliance systems up to date.
Nordea: A $35 Million Fine for Panama Papers Link
In August 2024, Nordea reached a settlement with the New York State Department of Financial Services (DFS), agreeing to pay a US$35 million fine related to deficiencies in its AML program. The investigation was sparked by the 2016 Panama Papers leak, which exposed Nordea’s role in facilitating offshore tax shelters and laundering money for clients through complex networks of shell companies.
The DFS found that Nordea had failed to conduct adequate due diligence on its correspondent banking relationships and did not maintain an effective transaction monitoring system. This case highlights the importance of maintaining strong AML programs and the need for financial institutions to closely monitor their international operations.
Conclusion: The Ongoing Importance of AML/CFT Compliance
The fines imposed on these institutions in 2024 reflect the increasing emphasis on financial crime compliance and the growing consequences for non-compliance. As regulators continue to tighten their scrutiny, institutions must ensure that their AML/CFT programs are robust, well-monitored, and up-to-date. The penalties outlined in this article underscore the risks that companies face when they fail to comply with AML/CFT regulations, and the long-term impact such violations can have on their reputation and bottom line.
Related Links
- US Department of Justice’s AML Guidelines
- FCA’s Financial Crime Report 2024
- Panama Papers Investigation Overview
- Finansinspektionen – Klarna Bank’s Fine
- The Importance of AML Controls in the Gambling Industry
Other FinCrime Central Articles about 2025 Penalties
- Jack Dorsey’s Cash App Pays $80 Million Over AML Compliance Issues
- BitMEX Faces $100 Million Penalty for AML Violations: A Critical Case
- Robinhood Hit with $30M Fine for AML Violations and Compliance Failures
Source: FINTECH Switzerland
