AML/CFT and Sanctions Enforcement Actions in 2025

A Historic Year for Banks and State Regulators

📅 December 9, 2025

This will likely go down as a historic year for the banking industry in a good way. Thus far, not one bank has faced a major penalty for violating U.S. AML/CFT or sanctions regulations. If this trend continues through December, it will be the first time this has occurred in over 20 years. Instead, U.S. AML/CFT enforcement actions targeted crypto exchanges, money transmitters, securities firms, and casinos, and OFAC enforcement actions focused mostly on corporates involved in trade transactions.

AML/CFT penalties have totaled over $1.1 billion, with crypto exchanges by far being fined the most ($927,500,000), followed by money transmitters ($161,200,000), securities firms ($46,900,000), and casinos ($32,300,000).
Sanctions-related penalties have totaled over $238 million, the largest of which was $216 million levied against GVA Capital Ltd., a San Francisco-based venture capital firm that knowingly managed investments for a sanctioned Russian oligarch.

Another significant development in 2025 was the first-ever joint AML/CFT-related enforcement actions by multiple state regulators. In January, the State Money Transfer Regulators of eight states entered an $80 million settlement with Block, Inc. related to shortcomings in its AML program, and in July five state regulators jointly penalized Wise US, Inc. $4.2 million for suspicious activity reporting deficiencies and transaction monitoring data integrity issues.

AML/CFT Enforcement Actions

Entity Name	Penalty Amount	Regulator	Institution Type	Case Description
Block, Inc. 1/15/2025	$80 Million	Multiple State Regulators	Money Transmitter	Block settled with the “State Money Transmission Regulators” of 8 states based on a multi-state examination related to the adequacy of Block’s BSA/AML program. Block neither admitted nor denied any violations, and the nature of the alleged violations were not disclosed as part of the agreement. The State Money Transmission Regulators likely had findings similar to those detailed in the Consent Order issued by the NYDFS in April 2025.
BitMEX 1/15/2025	$100 Million	DOJ	Crypto Exchange	BitMEX willfully failed to establish, implement, and maintain an adequate AML and KYC program.
LPL Financial, LLC. 1/17/2025	$18 Million	SEC	Securities Firm	LPL had failures in its customer identification program, including failure to close accounts for which it had not properly verified the customer’s identity. LPL also failed to close or restrict thousands of high-risk accounts, such as cannabis-related and foreign accounts, that were prohibited under LPL’s AML policies.
PEKEN Global Limited (KuCoin) 1/27/2025	$297 Million	DOJ	Crypto Exchange	KuCoin failed to implement effective AML and KYC programs, failed to report suspicious transactions, and failed to register with FinCEN.
Brink’s Global Services USA, Inc. 1/31/2025	$37 Million	FinCEN	Money Transmitter	Brink’s willfully violated the BSA and operated as a money transmitter within the U.S. without registering with FinCEN. The company facilitated cross-border bulk currency shipments without acting as the currency originator or consignee.
OKX 2/24/2025	$504 Million	DOJ	Crypto Exchange	OKX operated an unlicensed money transmitting business without registering with FinCEN or implementing an adequate AML program.
Robinhood Financial 3/7/2025	$26 Million	FINRA	Securities Firm	Robinhood failed to establish and implement reasonable AML programs, which caused it to fail to detect, investigate, or report suspicious activity. It also failed to establish a reasonable customer identification program, which resulted in the firm opening thousands of accounts when it had not reasonably verified the customer’s identity.
Resorts World Las Vegas (RWLV) 3/20/2025	$10.5 Million	NGCB	Casino	RWLV allowed high-stakes betting by those with a prior conviction of federal crimes, including illegal gaming and money laundering. RWLV failed to adhere to AML protocols, including identifying source of funds for a high-risk customer.
Block, Inc. 4/10/2025	$40 Million	NYDFS	Money Transmitter	Block was found to have deficient KYC and transaction monitoring protocols, and a backlog of SARs between 2018-2021. The backlog of SARs reportedly allowed for potential suspicious and illicit activity to occur. The program also had insufficient OFAC screenings and ineffective CDD policies.
MGM Resorts Int’l 4/18/2025	$8.5 Million	NGCB	Casino	MGM allowed high-stakes betting by those with a prior conviction of federal crimes, including illegal gaming and money laundering. MGM failed to adhere to AML protocols, including identifying source of funds for a high-risk customer.
US Tiger Securitiesand TradeUP Securities 4/25/2025	$950K	FINRA	Securities Firm	US Tiger and TradeUP are affiliated firms owned by an offshore holding company that services foreign financial institution omnibus accounts. Both firms failed to develop and implement reasonably designed AML programs. Their programs were not reasonably designed to detect and cause the reporting of potentially suspicious transactions. The firms also failed to conduct appropriate due diligence on correspondent accounts for foreign financial institutions.
Wynn Las Vegas, LLC 5/15/2025	$5.5 Million	NGCB	Casino	Wynn LV employees allowed international patrons to obtain and/or transfer money improperly for wagering and allowed wagers to be placed for other patrons at Wynn LV in violation of its AML compliance program.
Velox Clearing LLC 6/23/2025	$1.3 Million	FINRA	Securities Firm	Velox Clearing failed to establish and implement an AML program designed to detect suspicious activity and file timely reports. The firm’s AML program was not reasonably designed to address its high-risk customer base, its AML procedures were not customized to its business, and it failed to commit adequate staff and resources to its AML program.
Wise US, Inc. 7/9/2025	$4.2 Million	Multiple State Regulators	Money Transmitter	Wise failed to provide for an independent review of its AML/CFT program at a suitable frequency for its line of business and was found to have suspicious activity reporting deficiencies and transaction monitoring data integrity issues. Wise also failed to correct past deficiencies identified in prior examinations and independent audits.
Paxos Trust Company, LLC 8/7/2025	$26.5 Million	NYDFS	Virtual Currency Firm	Paxos was found to have deficiencies in its AML program related to digital asset transactions. Examiners found gaps in Paxos’s transaction monitoring and blockchain analytics processes, including delays in investigating suspicious activity and incomplete sanctions screening of counterparties.
EFG Capital Int’l 10/9/2025	$650K	FINRA	Securities Firm	EFG failed to establish and implement an adequate AML program tailored to its business model. The firm did not conduct independent AML reviews at appropriate intervals and failed to investigate or report suspicious activities involving high-risk foreign customers. FINRA also identified weaknesses in EFG’s customer due diligence and transaction monitoring systems.
Ceasars Entmt., Inc. 11/10/2025	$7.8 Million	NGCB	Casino	Ceasars allowed high-stakes betting by someone with a prior conviction of federal crimes, including illegal gaming and money laundering. Ceasars failed to adhere to AML protocols, including identifying source of funds for a high-risk customer.

Sanctions Enforcement Actions

Entity Name	Penalty Amount	Program	Institution Type	Case Description
Family International Realty LLC 1/16/2025	1.1 Million	Russia	Real Estate Company	Family International Realty (FIR) willfully transferred nominal ownership of three luxury condos owned by sanctioned Russian oligarchs to their non-sanctioned family members. The owner of FIR maintained strong financial ties with Russian oligarchs Valeri Abramov and Viktor Perevalov prior to their designations; following their designations, the owner devised a scheme to transfer nominal ownership of the oligarchs’ units to shell companies owned by Abramov and Perevalov’s family members.
Haas Automation, Inc. 1/17/2025	1 Million	Russia	Manufacturer	Haas indirectly supplied equipment, spare parts, and authorization codes to blocked Russian entities. It exported one convertible numerical machine (CNC) and 13 spare parts for the benefit of six SDNs or shadow SDNs between August 2019 and February 2022. For several of the blocked entity customers, Haas failed to conduct sufficient due diligence regarding the blocked entities’ ownership structures. For one entity, Haas failed to rescreen the designated customer against the SDN List for the relevant spare parts sale.
GVA Capital Ltd. 6/12/2025	216 Million	Russia	Private Equity Firm	GVA Capital Ltd., a venture capital firm located in San Francisco, knowingly managed an investment for sanctioned Russian oligarch Suleiman Kerimov while aware of his blocked status. GVA Capital’s founders maintained a personal relationship with Kerimov. Despite receiving third-party legal guidance cautioning against the sale or transfer of shares directly or indirectly involving Kerimov after his designation, GVA Capital coordinated with his nephew in his attempts to sell Kerimov’s assets held in GVA Capital-managed investment vehicles.
Unicat Catalyst Technologies, LLC 6/16/2025	3.9 Million	Iran, Venezuela	Petrochemical Company	Unicat supplied catalyst products and consulting services to customers in Iran and sold goods to a blocked Venezuelan entity. Despite being aware of U.S. sanctions against these countries, Unicat’s former CEO knowingly directed sales to Iran, working through affiliates and suppliers in the UAE, Netherlands, and China. These transactions were often concealed through intermediaries and cash payments. Unicat also sold products to a Venezuelan state-owned company using similar methods.
Key Holding, LLC 7/2/2025	609,000	Cuba	Logistics Company	Key Holding’s Colombian subsidiary managed the logistics for freight shipments from Colombia to Cuba. It managed the logistics for 36 freight shipments containing foodstuffs, oil well machinery components, towels, and electric forage choppers that were not eligible to be licensed by OFAC. Key Holding U.S. was not aware of Key Colombia’s shipments to Cuba, and Key Colombia was unaware that it was subject to the Cuban Assets Control Regulations.
Harman International Industries, Inc. 7/8/2025	1.5 Million	Iran	Electronics Company	Harman shipped goods to a UAE-based distributor knowing that the goods would be reexported to Iran. Harman did not have a formal system for monitoring or auditing sanctions-related risks and had only one employee responsible for managing U.S. sanctions and export control risks. The individual did not have expertise or screening tools to adequately monitor these risks, nor did Harmon’s in-house attorney have the training, time, or resources to develop adequate expertise on OFAC regulations. Harman also did not extend its policies and controls sufficiently throughout its organization, including overseas employees.
Interactive Brokers LLC 7/15/2025	11.8 Million	Cuba, China CMIC, GloMag, Iran, Russia, Syria, Venezuela	Securities Firm	Interactive Brokers LLC (IB) provided services to individuals and entities in violation of numerous sanctions, including: • Nearly 12,000 transactions with more than 200 accountholders located in Iran, Cuba, Syria, and Crimea. • 259 customer funds transfers to accounts at blocked Russian banks, erroneously believing that relevant wind-down general licenses authorized the transfers. • 18 transactions related to customers trading in securities of an entity owned 50 percent or more by Xinjiang Production and Construction Corps (a GLOMAG SDN).
Fracht FWO Inc. 9/3/2025	1.6 Million	Iran, Terrorism, Venezuela, WMD	Freight Forwarder	Fracht FWO chartered a Venezuelan state-owned aircraft operated by EMTRASUR, a subsidiary of the blocked Venezuelan carrier CONVIASA, using an aircraft previously identified by OFAC as blocked property of Mahan Air, an Iranian airline sanctioned under multiple authorities. The aircraft was staffed by an Iranian crew associated with Mahan Air.
ShapeShift AG 9/22/2025	750,000	Cuba, Iran, Sudan, Syria	Digital Asset Exchange	ShapeShift processed over 17,000 digital asset transactions totaling approximately $12.57 million for users located in Cuba, Iran, Sudan, and Syria, without any sanctions screening program in place. OFAC considered the company’s small size, defunct status, and cooperation as mitigating factors.

Recorded Webinar:

2025 in Review, 2026 in Sight: Trends & Turning Points

Watch our recorded webinar where we review the most important counter-illicit finance developments of this year and discuss what’s on the horizon for 2026.

2025 has been a busy year, with developments in sanctions, export controls, anti-money laundering, countering terrorism financing and other financial crimes.

Led by senior experts from IFI and K2 Integrity, this webinar assessed the most significant developments in financial integrity in 2025 and the outlook for 2026.

View Recording

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