Germany’s BaFin Imposes Largest Ever Fine On JPMorgan For AML Lapses

Germany’s financial regulator, BaFin, has imposed a fine of €45 million (about US $52 million) on the Frankfurt-based subsidiary of JPMorgan for anti-money-laundering (AML) failings.

The failings relate to the period between October 2021 and September 2022, during which the bank “systematically” filed its Suspicious Activity Reports (SARs) late.

BaFin described the banks’ internal processes as having breached its supervisory obligations in flagging and reporting potential illicit transactions.

This is reportedly the largest fine BaFin has ever imposed on a financial institution.

As a large, globally active bank, JPMorgan is under heightened scrutiny for compliance. The fine signals that even major players are held to strict standards in Germany.

For the German market, this highlights ongoing enforcement intensity and the importance of robust AML controls. Some commentary suggests Germany is still at a “crossroad” in its AML reforms.

Meanwhile, JPMorgan has stated the issue relates to historical findings, and said that the delayed filings did not impede official investigations.

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For banks and financial-institutions in Germany and Europe, this serves as a reminder to ensure their AML frameworks (especially SAR/SAR-reporting processes) are effective, timely and well-governed.

For regulators and policy observers, this is a sign that Germany is willing to impose significant fines, even on large international banks.

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