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AML/KYC Enforcement · 5 cases · 2021–2024

$10.5B+ in Fines for
Monitoring Failures

TD Bank: $3.1B — the largest FinCEN penalty against a bank in history. Binance: $4.3B — the largest crypto enforcement ever. In every case, the firms could not prove their transaction monitoring was actually working.

Featured Cases

Binance

November 2023

$4.3B

Largest crypto enforcement action ever. Admitted insufficient AML and sanctions controls, failed customer identification and sanctions evasion detection. CEO Changpeng Zhao pleaded guilty and resigned.

Source: DOJ Press Release

TD Bank

October 2024

$3.1B

Largest FinCEN penalty against a bank in history. Failed to maintain adequate AML program from 2014-2023. Three money laundering networks laundered $600M+ through the bank. Employees bribed to open accounts. Transaction monitoring system had known gaps that were never fixed.

Source: FinCEN

Danske Bank

December 2022

$2B+

Estonian branch processed approximately $160B in suspicious transactions from 2008-2016, many from Russia. Bank pleaded guilty to conspiracy to commit bank fraud. Failed to maintain adequate AML monitoring records.

Source: SEC Press Release

British American Tobacco

April 2023

$629M

Sold tobacco products to North Korea through a Singapore subsidiary, evading US sanctions. Largest OFAC fine against a non-financial institution ever.

Source: US Treasury

Capital One

January 2021

$390M

Willfully failed to file thousands of Suspicious Activity Reports and negligently failed to file thousands of Currency Transaction Reports related to its Check Cashing Group from 2008-2014.

Source: FinCEN

What went wrong in every case

The same monitoring failures appear across traditional banking, crypto exchanges, and multinational corporations.

  • Transaction monitoring had known gaps — TD Bank's deficiencies went unfixed for 9 years
  • Customer identification failures — insufficient KYC controls, sanctions evasion undetected
  • Suspicious activity went unreported for years — thousands of SARs never filed
  • Compliance programs existed on paper but couldn't prove actual transaction monitoring
  • Fines are existential — $3.1B and $4.3B, not cost-of-business penalties

How tamper-proof evidence changes the equation

Cryptographic audit trails make it mathematically impossible to alter or destroy records without detection.

Monitoring is Cryptographically Proven

Every screening decision gets a cryptographic receipt at the moment it occurs. When regulators ask 'was this transaction screened?' — the answer is a mathematical proof, not a log entry that could have been generated after the fact.

Gaps in Monitoring Are Detectable

TD Bank's monitoring system had known gaps for years. With cryptographic audit trails, missing screening events create provable chain gaps — making it impossible to silently skip transactions.

Compliance Becomes Continuous

Instead of point-in-time audits that miss years of violations, cryptographic receipts provide continuous proof that AML controls were active and functioning. Not 'we had a program' — 'here's the mathematical proof it ran on every transaction.'

Ready to make your audit trail tamper-proof?

Create your free account and start protecting your data with cryptographic evidence that can't be altered or destroyed.