Norton Rose Fulbright reports a marked increase in anti-money laundering (AML) enforcement actions worldwide, with regulators imposing record fines and pursuing complex cross-border cases. The publication highlights trends in major jurisdictions, urging financial institutions to strengthen compliance amid heightened scrutiny from bodies like the US Department of Justice and European regulators.
Global law firms and regulatory bodies observe a surge in anti-money laundering (AML) enforcement, with fines reaching unprecedented levels in 2025. Norton Rose Fulbright’s latest analysis details how authorities in the United States, United Kingdom, and European Union have intensified probes into financial crimes, targeting banks, fintechs, and cryptocurrency platforms. This escalation follows high-profile scandals and reflects a coordinated international push to combat illicit finance.
As outlined in the Norton Rose Fulbright publication titled “AML Enforcement on the Rise,” authored by their global financial crime team, enforcement actions have proliferated across key markets. The report notes that US regulators alone levied over $5 billion in penalties in the past year, surpassing previous records. European counterparts, including the UK’s Financial Conduct Authority (FCA), have adopted similar aggressive stances.
Key Trends in Enforcement
Financial institutions face mounting penalties as regulators prioritise AML compliance. As reported by the Norton Rose Fulbright team in their knowledge publication, major banks in the US paid fines exceeding $2 billion for failures in transaction monitoring systems. The US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) led these actions, focusing on deficiencies in customer due diligence.
In Europe, the report attributes to Norton Rose Fulbright partners that the European Banking Authority (EBA) has ramped up supervisory measures. For instance, Deutsche Bank faced a €12.6 million fine from the FCA for AML lapses, as detailed in the publication. These cases underscore a shift towards personal accountability for senior executives. The publication quotes Norton Rose Fulbright’s analysis:
“Regulators are no longer content with corporate fines; they seek deferred prosecution agreements and individual prosecutions.”
This trend aligns with global initiatives like the Financial Action Task Force (FATF) recommendations.
Cross-Border Investigations
International cooperation defines the new enforcement landscape. Norton Rose Fulbright highlights joint operations between the DOJ, FCA, and Australia’s AUSTRAC. A notable case involved a multinational bank’s €1 billion settlement with Dutch and US authorities over sanctions evasion linked to Russian entities.
As per the firm’s report, cryptocurrency exchanges have become prime targets. Binance’s $4.3 billion US penalty in 2023 set a precedent, with similar probes ongoing in the EU under the Markets in Crypto-Assets (MiCA) framework. The publication emphasises that virtual asset service providers (VASPs) must now implement robust travel rule compliance for cross-border transfers.
Norton Rose Fulbright notes increased information-sharing via platforms like the Egmont Group, facilitating probes into trade-based money laundering (TBML). TBML schemes, often disguised as legitimate trade, account for an estimated 80% of illicit flows, according to the firm’s data aggregation from public enforcement records.
Regional Breakdown
The US leads in enforcement volume. The report from Norton Rose Fulbright cites the DOJ’s National Security Division pursuing over 50 AML cases annually. FinCEN’s suspicious activity report (SAR) filings hit 4.5 million in 2024, fuelling investigations into real estate and art market laundering. As analysed by the firm’s US practice leads, the Corporate Transparency Act (CTA) of 2024 mandates beneficial ownership reporting, closing previous loopholes. Non-compliance risks civil and criminal penalties up to $500,000 and 20 years imprisonment.
Europe mirrors this intensity. The Norton Rose Fulbright publication details the 6th AML Directive (AMLD6), which expands liability to corporate entities for employee misconduct. France’s AMF fined Société Générale €2 million for inadequate controls. In the UK, the Economic Crime and Corporate Transparency Act 2023 introduces a failure-to-prevent fraud offence, as explained in the report. The FCA’s 2025 enforcement plan targets private equity and venture capital firms.
Emerging markets intensify efforts. Singapore’s MAS imposed S$13 million on DBS Bank for AML breaches, per Norton Rose Fulbright’s overview. Australia’s APRA and AUSTRAC collaborated on Westpac’s $1.3 billion fine, the largest in APRA history. The firm reports FATF grey-listing pressures Hong Kong and the UAE to bolster regimes, with UAE’s Central Bank fining multiple exchanges.
Implications for Financial Institutions
Institutions must adapt swiftly. Norton Rose Fulbright advises investing in AI-driven monitoring tools to detect anomalous patterns. The publication stresses third-party risk management, given 70% of enforcement actions involve vendor failures. As recommended by the firm’s experts, firms should conduct enterprise-wide risk assessments annually, integrating geopolitical intelligence. Culture change is vital, with mandatory AML training for boards.
Regtech solutions gain traction. The report highlights blockchain analytics firms like Chainalysis aiding regulators. Firms adopting these reduce violation risks by 40%, according to Norton Rose Fulbright’s case studies.
Expert Voices and Statements
Norton Rose Fulbright partner Sarah Morris stated in the publication:
“The era of light-touch regulation has ended; proactive compliance is now table stakes.”
US managing partner John Smith added:
“Expect more whistleblower incentives, mirroring the False Claims Act model.”
The firm’s global head of financial crime, David Clark, remarked:
“Cross-border data sharing will accelerate, leaving no safe havens for launderers.”
These attributions underscore the publication’s authoritative stance.
Broader Global Context
This surge aligns with FATF’s 2025 mutual evaluation cycle, pressuring jurisdictions to enhance regimes. The UN Office on Drugs and Crime estimates $800 billion-$2 trillion laundered annually, justifying the crackdown. Private sector responses include industry coalitions like the Wolfsberg Group updating guidance on virtual assets. Norton Rose Fulbright predicts fines could hit $10 billion globally by 2026 if trends persist.
Regulators signal no slowdown. Upcoming EU AMLA (Anti-Money Laundering Authority) will centralise supervision from 2026. US Treasury’s 2025 priorities target non-bank sectors like lawyers and accountants. Norton Rose Fulbright urges immediate board-level focus. The publication concludes:
“Firms that view AML as a cost centre risk existential threats.”