FinCEN hits broker-dealer with $125M BSA penalty for repeat AML failures
Broker-dealers under prior AML consent orders face heightened enforcement risk after FinCEN imposed a $125 million penalty on UBS Financial Services for willful, repeated BSA violations and failure to remediate 2018 deficiencies.
FinCEN assessed a $125 million civil money penalty against UBS Financial Services Inc. for willful Bank Secrecy Act violations, marking the largest such penalty against a broker-dealer. The action follows a 2018 consent order and centers on failures to monitor over 61,500 foreign currency wires totaling more than $10.5 billion, deficient customer due diligence for high-risk clients (including Russian and Latin American ties), and untimely SAR filings. After crediting $48 million for related SEC, CFTC, and FINRA payments, UBSFS owes $62 million, with up to $15 million waivable based on qualifying compliance spending and full adherence to the order. The settlement requires a SAR look-back and independent AML program review. FinCEN’s focus on recidivism, data governance, and dynamic CDD signals that covered institutions must validate remediation, ensure complete transaction monitoring data feeds, and maintain continuous risk reassessment.