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Fenergo Study: U.S. Financial Regulatory Penalties Plunge 61% Amid Regulatory Capacity Strain but Lighter Enforcement Not Likely
Fenergo, the leading provider of AI-powered solutions for Know Your Customer (KYC), Anti-money Laundering (AML), Transaction Monitoring and Client Lifecycle Management (CLM), has released its annual report analyzing global financial institution enforcement actions related specifically to AML compliance breaches from January 1, 2025, to December 31, 2025. The report reveals fines issued by U.S. regulators fell by 61% YoY, as workforce shifts and enforcement capabilities tempered enforcement activity.
FENERGO’S FINDINGS:
- Global:
- Global penalties for failing to comply with AML, KYC, sanctions and customer due diligence (CDD) regulations totaled $3.8 billion in 2025, down from $4.6 billion in 2024 and $6.6 billion in 2023.
- United States:
- Enforcement scale and activity
- Across 40 countries spanning APAC, EMEA and North America, the U.S. led in monetary fines with a total of $1.67B penalties, followed by France at $1.11B and Switzerland at $342M.
- U.S regulators issued 31 fines, down 34% YoY (from 47 in 2024).
- The single largest US penalty was issued by the Department of Justice (DOJ) to a former Swiss bank and financial services firm for tax evasion at $511M.
- Key enforcement drivers
- The majority of the total value of U.S. penalties fell under the broad category of AML but throughout 2025 there were several enforcement actions directly attributable to specific violations:
- Sanctions-related penalties amounted to approximately $243M, with the largest fine at $216M, issued to GVA Capital a venture capital firm based in San Francisco, California, for violating OFAC’s Ukraine-/Russia-related sanctions.
- SARs-related failures accounted for approximately $45M.
- Transaction monitoring and CDD compliance breaches combined represented approximately $3.66M. With the largest transaction monitoring-related fine accounting for $1.3M.
- The majority of the total value of U.S. penalties fell under the broad category of AML but throughout 2025 there were several enforcement actions directly attributable to specific violations:
- Enforcement by type
- Digital assets firms faced the largest share of enforcement penalties, totaling $728M, representing 43% of U.S. fines levied.
- Banks were penalized a total of $511M (30%) while buy-side firms accounted for $239M fines (14%).
- Money services firms were issued a total of $146M fines, representing of 9% total U.S. fines incurred.
- Enforcement scale and activity
Commenting on the findings, Rory Doyle, Head of Financial Crime Policy at Fenergo: “The US is still the most significant AML enforcement jurisdiction in the world, even though fines fell by 61% in 2025. That drop is more about capacity and priorities than any softening of expectations. Staffing cuts across regulators and the prolonged US government shutdown slowed things down, but this is temporary. Once capacity returns, enforcement will follow. The research indicates that regulatory agendas remain firm on ensuring a secure financial ecosystem. As enforcement capacity in the U.S. are improved financial institutions should continue to anticipate a more active regulatory landscape, making it paramount for institutions to ensure they have the proper processes and systems in place.”
To receive a copy of the report, join Fenergo’s webinar on February 3rd
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