Year in review: The biggest financial crime cases and AML fines of 2023


2023 was far from a quiet year when it came to financial crime. Across the world, we witnessed a series of devastating fraud cases that left a lasting impact. Additionally, there were some eye-watering fines imposed on firms for Anti-Money Laundering (AML) failures, shedding light on the urgent need for stricter regulations. 

From high-profile fines to instances of regulatory non-compliance, and scandals that sent shockwaves through the financial system in the past year, it is clear that the fight against financial crime is an ongoing battle. 

Binance breaks records with near $5bn fine for AML failings

Once the world’s largest cryptocurrency exchange, Binance was slapped with a record-breaking fine of $4.3billion in November for its failings in money laundering prevention amid accusations of laws being violated in pursuit of growing market share.

Founded by Changpeng Zhao, Binance faced allegations of violating the Bank Secrecy Act, allowing customers to trade on its platform without due diligence KYC checks in place. Zhao is reported to have believed “requiring all customers to provide KYC information would mean that some customers would choose not to use Binance and others would be rejected by the compliance process—both of which would interfere with Binance gaining market share.”

Without proper due diligence in place, bad actors were effectively allowed to transact with sanctioned individuals and crime networks without restriction, funnelling dirty money through the platform that has since been reported to have been linked with illegal drugs, terrorism, and human trafficking. It is believed that more than 100,000 illegal transactions were processed through the platform without an ounce of suspicion. 

High street gambling chain fined £20m for failures in social responsibility and anti-money laundering

Following an investigation by the Gambling Commission, three gambling businesses owned by William Hill Group were ordered to pay a total of £19.2m in March for its failings in social responsibility and anti-money laundering processes. 

This ruling comes just over a year after 888 UK Limited, the parent company of William Hill, was handed a financial penalty of nearly £10m and warning for similar failings. 

In a statement issued by the Gambling Commission, “the failings we uncovered were so widespread and alarming serious consideration was given to licence suspension.” With the Commission coming down hard on William Hill, the group immediately took action to implement improvements that resulted in the largest enforcement payment in the regulator’s history. 

Just some of William Hill’s failures included not having sufficient controls in place to protect new customers, not considering the velocity of spend and duration of play which resulted in a customer being able to open an account and spend £23,000 in 20 minutes without any checks, allowing customers to deposit large amounts without conducting appropriate checks, customers being able to bet large amounts of money without being monitored or required to provide Source of Funds evidence, and AML staff training provided insufficient information on risks and how to manage them. 

Deutsche Bank hit with historic sanction and AML failings 

In a case that started back in 2015, Deutsche Bank was ordered to pay more than $186 in July of this year for violating sanction and AML orders by the Federal Reserve Board. The consent order issued by the Fed required Deutsche Bank to formally address significant violations of regulatory standards.

In 2015, the bank was issued with a consent order due to insufficient policies and procedures in place to ensure compliance with US sanctions against countries including Iran, Libya, Syria, Burma and Sudan. Hit with a $58m fine at the time, Deutsche Bank has since been pulled up by the Fed once again for violations of the historic consent orders. 

Investigations by the Fed have since found that Deutsche Bank made “insufficient progress in its remediation efforts pursuant to the OFAC and AML orders, including with respect to compliance oversight, customer due diligence, transaction data, transaction monitoring and filtering, suspicious activity reporting, and facilitating independent third-party reviews.” (The Federal Reserve System)

The bank has since agreed to submit its plans regarding how it will improve its governance, risk management and controls to avoid further violations of consent orders. 

Six jailed in £100m+ Dubai money laundering plot

Six individuals involved in a money laundering scheme, responsible for facilitating the transportation of £104 million in illegally obtained cash, were sentenced in July for money laundering offences and received sentences ranging from 12 to 42 months imprisonment.

The defendants acted as “money mules,” transporting the illegally obtained cash from the UK to Dubai. The group made multiple trips carrying suitcases filled with cash, knowing or suspecting its criminal origin. Abdulla Alfalasi, identified as the mastermind, orchestrated 83 successful trips over 18 months, involving a total of £104 million. The suitcases carried by the defendants typically contained up to £500,000, and they were paid a mere £3,000 for each trip. Alfalasi, originally from Dubai, received a nine-year jail term.  

The Crown Prosecution Service emphasised the scale of this money laundering operation and its significant impact on the UK economy and national security. Money laundering, considered an integral aspect of organised crime, not only enriches individuals involved but also funds future criminal activities, posing an ongoing threat to the financial ecosystem. 

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