Fenergo, the leading provider of digital solutions for client lifecycle management (CLM), know your customer (KYC) and transaction monitoring, today released its annual findings on global financial institution enforcement actions, which reveal that the value of penalties imposed on firms declined year-on-year by 18% but reflects significant regional divergence.  

Penalties for failing to comply with anti-money laundering (AML), KYC,sanctions and customer due diligence (CDD) regulations totalled $3.8 billion in 2025, down from $4.6 billion in 2024 and $6.6 billion in 2023. While global fines declined for a second consecutive year, enforcement activity diverged sharply by region. Fines issued by North American regulators fell by 58%, while EMEA and APAC penalties rose by 767% and 44% respectively, driven largely by the conclusion of long-running investigations and intensified scrutiny in specific sectors. 

“The UK continues to show a steady and robust approach to AML enforcement, and the fines we saw in 2025 reflect just how long regulatory investigations can take,” comments Rory Doyle, head of financial crime policy at Fenergo. In December 2025, the Financial Conduct Authority (FCA) fined a UK building society $59 million (£44 million) for transaction monitoring failures that enabled COVID furlough fraud totalling $36.4 million (£27.3 million) in one case. “The high-profile case is a good example of that. It shows how issues that emerged during the COVID period are now working their way through the system and feeding into enforcement outcomes years later.” 

The single largest penalty of 2025, at $985 million (EUR835 million), was issued to a Swiss bank by French authorities in relation to AML failings. As a result, France became the second-largest enforcer globally ($1.11 billion) behind the US ($1.676 billion), a dramatic increase from 2024.  

Despite regulatory progress, digital assets firms remain overrepresented in major AML fines, reflecting the sector’s ongoing maturity challenges. Almost one quarter of the top ten highest- value fines involve digital asset firms as rapid growth in transaction volumes and stablecoin usage has outpaced compliance capabilities. While progress in this sector is evident, compliance maturity still lags behind risk exposure, especially with the growing expectation that digital asset firms adopt bank-grade AML controls.  

“As enforcement rebounds in key jurisdictions, firms that fail to modernise their financial crime ecosystem will remain exposed,” Doyle continues. “Those that prioritise investment in leading-edge technology with AI at the forefront, will be able to demonstrate robust AML controls and regulatory alignment while being far better positioned for the next wave of scrutiny.”