AML Fines Globally 2024: 2024 Statistics, Trends, and Analysis

Methodology

These figures come primarily from Fenergo's "AML Enforcement Action in 2024" report, published in February 2025, which tracks global regulatory enforcement actions against financial institutions for AML, KYC, sanctions, and related financial crime violations. Fenergo compiled the data from regulatory announcements, consent orders, court filings, and press releases across multiple jurisdictions throughout calendar year 2024.

Individual case figures were verified against primary sources: U.S. Department of Justice press releases, FinCEN's civil money penalties register (including Consent Order 2024-02 against TD Bank, published October 10, 2024), OCC enforcement action records, Federal Reserve Board orders, and the UK FCA's Final Notice for Starling Bank (October 2024).

Three caveats apply. First, Fenergo's reports before 2021 included data privacy (GDPR) and MiFID-related fines in headline totals, so year-over-year comparisons before 2021 are not like-for-like. Second, GBP-to-USD conversions for UK actions use approximate 2024 exchange rates. Third, non-public settlements are excluded entirely. Regulatory bodies in multiple jurisdictions resolve cases under undisclosed terms, particularly in the EU and Asia-Pacific, meaning actual global enforcement totals exceed any published aggregate.

Full data table

Major publicly disclosed AML and sanctions enforcement actions, global, 2024:

Sources: ABA Banking Journal (November 2024), FinCEN Consent Order 2024-02, OCC enforcement register, Federal Reserve enforcement database, FCA Final Notice (October 2024), NYDFS Consent Order (August 2024). The DOJ + FinCEN components against TD Bank ($3.1 billion combined) represent the primary criminal plea resolution; OCC and Federal Reserve orders were simultaneous but separate.

Key findings

• TD Bank's settlement dominated the year. The bank's four-regulator resolution in October 2024 totaled approximately $3.67 billion. The DOJ component alone, $1.8 billion, is the largest penalty ever imposed under the Bank Secrecy Act. The FinCEN portion, $1.3 billion, set a record for any U.S.-chartered depository institution. The bank failed to detect and report over $670 million in suspicious transactions linked to criminal networks, across a compliance failure running from January 2014 to October 2023. One institution. One decade of systemic failure.

• Bank-specific fines rose 522%, but context matters. In 2023, crypto firms drove 69% of global penalties; traditional banks received comparatively little. In 2024, the position reversed: total bank fines globally reached $3.65 billion, per Fenergo. Strip out TD Bank and the underlying figure is modest. The 522% number tells you about one institution's extraordinary failure, not a broad surge in bank-sector enforcement.

• Transaction monitoring failures drove $3.3 billion of the 2024 total. Fenergo identified monitoring system deficiencies as the dominant root cause across the year's enforcement actions. That's 72% of all global fines tracing directly to failures in transaction surveillance, alert investigation, or SAR filing workflows. It's the same pattern that appeared in the HSBC 2012 enforcement action and it hasn't gone away.

• Non-U.S. enforcement remained thin. U.S. regulators issued approximately $4.3 billion of the global $4.6 billion total. Every other jurisdiction produced roughly $300 million combined. The most visible non-U.S. actions were the UK FCA's £28.96 million fine against Starling Bank (October 2024) and NY DFS's $35 million action against Nordea Bank (August 2024). Starling had been screening against 39 of 3,088 designated persons under financial sanctions since 2017. Six years. The FCA described the controls as "shockingly lax."

Year-over-year trends

The headline swings sharply from year to year, almost entirely because of single mega-cases:

Source: Fenergo annual AML enforcement reports (2021–2024).

Strip out the dominant case from each year and the underlying baseline looks different. Excluding Binance from 2023 leaves roughly $2.3 billion. Excluding TD Bank from 2024 leaves roughly $1.5 billion. The base, absent headline-grabbing outliers, has actually been declining.

The longer arc is more revealing. Financial Crime News documented $45.679 billion in major AML and sanctions fines globally from 2000 to end 2024 (actions above $10 million each). AML cases generated $27.886 billion across 85 actions. Sanctions cases generated $17.793 billion across 26. That 25-year cumulative puts individual years in perspective: enforcement is lumpy, not linear.

One structural shift to track: the EU's AML Regulation package was adopted in 2024, creating the Anti-Money Laundering Authority (AMLA) as direct supervisor of the EU's highest-risk financial institutions. AMLA starts operations in 2027. European enforcement totals are expected to climb from 2028 onward as the first AMLA-led cases conclude. The current 95%/5% U.S./rest-of-world split will narrow.

What this means for compliance teams

Three things stand out from the 2024 data.

Transaction monitoring coverage gaps are still the most expensive compliance failure on record. $3.3 billion out of $4.6 billion in 2024 penalties traced to inadequate monitoring. "Adequate" here means both coverage (the right rules running against the right account populations) and response (alerts investigated and escalated before they become regulatory findings). TD Bank's failure ran across both dimensions for a decade.

Sanctions screening list integrity is now a board-level control question. The Starling Bank case confirmed that regulators don't treat a partial screening list as a configuration error. Starling screened against 39 of 3,088 designated persons for six years without anyone confirming the list was complete. It wasn't a gap in detection logic. It was a governance failure. Compliance teams that haven't audited their screening list coverage and update frequency in the past 12 months are carrying undisclosed risk.

TD Bank's DOJ case is also a FATF Recommendation 20 story. The bank identified suspicious patterns in some cases and didn't escalate them into formal SAR filings. Prosecutors documented specific criminal networks using retail branches to move over $670 million. Detection without filing is not a defence; it may be an aggravating factor.

Multi-agency coordination is now standard. All four U.S. regulatory actions against TD Bank landed on the same day. That coordinated model means a compliance failure is no longer contained by which regulator discovers it first. The response is regulatory compliance automation that produces auditable records across every decision point, and customer due diligence programs that document their own coverage rather than waiting for examiner spot-checks to surface the gaps.

Sources

• Fenergo, "AML Enforcement Action in 2024," February 2025
• Fenergo, "Regulatory Penalties in North America Account for 95% of Global Financial Penalties in 2024," February 2025
• FinCEN, Consent Order 2024-02 (TD Bank N.A.), October 2024
• ABA Banking Journal, "TD Bank agrees to pay $3.1 billion to resolve AML allegations," November 2024
• FCA, "FCA fines Starling Bank £29m for failings in financial crime systems and controls," October 2024
• Fenergo, "Global financial institution AML and regulatory fines soar in 2023," 2024
• OFAC, Settlement with Binance Holdings Limited, November 2023
• Financial Crime News, "Bank and FI AML/Sanctions Fines and Penalties in the 21st Century," 2025