$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
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 ReleaseTD Bank
October 2024
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: FinCENDanske Bank
December 2022
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 ReleaseBritish American Tobacco
April 2023
Sold tobacco products to North Korea through a Singapore subsidiary, evading US sanctions. Largest OFAC fine against a non-financial institution ever.
Source: US TreasuryCapital One
January 2021
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: FinCENWhat 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.'
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Create your free account and start protecting your data with cryptographic evidence that can't be altered or destroyed.