Fenergo, the leading provider of digital solutions for client lifecycle management (CLM), know your customer (KYC) and transaction monitoring, announced today the findings of its annual report on global financial institution enforcement actions. Global regulatory fines in 2024 saw a decline in value from US$6.57 billion in 2023 to US$4.6 billion—a reduction of 30%. The APAC region as a whole saw the total penalty value drop by 98%, from US$1.41 billion in 2023 to US$32.1 million. 

However, Singapore’s tightened compliance measures and enforcement actions have brought steady increases in fines from a total value of US$748,693 in 2021 to US$818,329 in 2022 (up by 9.3%), and to US$2,681,162 in 2023 (a marked 228% increase). In 2024, the trend continued with regulatory fine values increasing 22% to US$3,281,066. Apart from greater regulatory scrutiny of Singapore’s financial institutions and industries, this increase has also been influenced by factors such as increased technology adoption by regulatory bodies and subsequent efficiency gains. 

In Singapore, fines were predominantly in relation to AML/ KYC and Transaction Monitoring (TM) breaches in 2024 with values of US$1.84 million and US$1.43 million respectively. Transaction Monitoring (TM) violations also dominated the global landscape in 2024 with a total of US$3.3 billion in fines issued. This was followed by KYC fines (US$105 million) and Anti Money-Laundering (AML) (US$1.19 billion), with ESG as an emerging area with a value of US$37.69 million.  

The largest enforcement action of the year, US$3.18 billion, was levied against TD Bank by US regulators for deficiencies in its transaction monitoring systems. Across APAC, penalties for AML and ESG violations were the most significant in value. The most punitive fine issued for AML breaches in APAC was issued by the People’s Bank of China (PBOC) at US$3.9 million to Zhejiang Aerospace Electronic Information Industry. In Australia, the Australian Securities & Investments Commission (ASIC) led the charge globally with landmark fines for ESG breaches to Vanguard ($8.8 million) and Mercer ($7.4 million) 

In other regions, North America (NAM) maintained its position as the most punishing region for regulatory fines, with a total of $4.33 billion in penalties issued in 2024—a modest decline of 15% compared to 2023, but while the total value of fines declined globally, there were variances in each region. In the EMEA region, fines increased by 170 % rising from $75.96 million to $219.2 million, while in the UK, fines rose sharply by 156%, from $25.26 million to $64.74 million.  

Segment-wise, there is a marked shift with emphasis on traditional financial institutions, with banks incurring fines of $3.65 billion as compared to digital assets ($762.9 million), evidence that banks are being subject to increasing regulatory scrutiny globally. 

Rory Doyle, head of financial crime policy at Fenergo, has commented on the findings, predicting that in 2025, the Singapore market can expect more investigations and enforcement action: 

“Learning from the financial scandals in late 2023, and with the formation of private-public partnerships such as COSMIC Singapore regulators and Finance Intelligence Units (FIUs) now have access to more data. This allows them to identify issues more efficiently, and act more quickly in cracking down or mitigating breaches from occurring. 

As China tightens control over nefarious financial activity, particularly with its new regulatory framework for crypto, there will be a potential outflow of funds to other economies such as Singapore. This emphasis on regulation or investigation on crypto also means that traditional fund transfers may become the more popular means of fund outflow into Singapore. 

With this knowledge, we anticipate that MAS will be more vigilant, not just with scrutiny and enforcement action on violators, but to ensure that all companies stay ahead of the curve and comply. MAS has historically been very cautious and fair with their penalties, but as the year-on-year increase in fines indicates, they will be sounding a clarion call to the market by issuing more punitive fines in 2025. 

With the shift in focus globally on the banking sector and in response to recent scandals, we foresee a surge enforcement action in Singapore across all financial services sectors. It is in the best interest of financial institutions to deploy robust infrastructures for AML thus streamlining processes for KYC, suspicious activity reporting and transaction monitoring. This will ultimately reduce the risk of financial crime and mitigate costly enforcement action and reputational harm.”