Anti-Money Laundering Fines within UK and SA – How to Avoid Them

anti-money laundering fines for the UK and SA

Top UK Financial Conduct Authority Fines of 2023

Staying on the right side of regulators is a major concern for financial institutions worldwide. Misunderstanding compliance measures may lead to hefty anti-money laundering  fines (AML) that can damage reputations and bottom lines. In the UK and South Africa, regulators have doled out multi-million pound/rand penalties to banks, insurers and others for significant compliance failures in recent years.  

But what exactly are companies getting wrong when it comes to AML procedures? And how can your organisation avoid similar fines? This article analyses the most significant UK and South African AML penalties of 2023, highlighting the specific lapses that incurred regulators’ scrutiny. By understanding the compliance failures that triggered these record fines, your institution can conduct a health check of your AML strategy to help prevent any shortcomings.

The following practical tips can help to evaluate your existing controls in customer due diligence, transaction monitoring, record keeping, reporting obligations, risk management frameworks and staff training. By learning from others’ mistakes, businesses can proactively close loopholes and ensure their AML regime meets regulatory expectations, keeping company reputation and finances intact.

Thus far in 2023, the fines imposed by the Financial Conduct Authority (FCA) total around £53 million, indicating some progress in compliance from past penalty cases. However, though lower overall, substantial fines for major institutions reveal lingering deficiencies that demand earnest financial crime prevention efforts across the finance sector.

ED&F Man Capital Markets Ltd – £17.2 million for failures overseeing cum-ex trading enabling illegal tax refunds.

Equifax Ltd – £11.1 million for a security breach exposing customer data and misleading public statements.  

Guaranty Trust Bank (UK) Ltd – £7.6 million for insufficient anti-money laundering (AML) controls like risk assessments.

ADM Investor Services International Ltd – £6.4 million for inadequate AML systems, including outdated policies.

Al Rayan Bank PLC – £4 million for neglecting the appropriate source of funds checks. 

Bastion Capital London Ltd – £2.4 million for the ignorant oversight of potential financial crime cum-ex trades.

Summary of fines - UK AML Compliance breakdowns:

Summary of anti-money laundering fines for the UK 2023

South African SARB anti-money laundering fines overview (2021 - 2023)

Sanlam Life – R1 million fine for failures in enhanced due diligence for prominent persons, cash threshold reporting and suspicious transaction reporting 

Fedgroup Life – R140,000 fine for deficiencies in AML/CFT training and AML/CFT governance oversight

Deutsche Bank AG Johannesburg Branch – R28 million fine (R10 million suspended) for non-compliance in customer due diligence, record keeping and AML/CFT governance  

Discovery Life Limited – R1.5 million fine (R500,000 suspended) for failures in cash threshold reporting, risk management compliance, AML/CFT training and AML/CFT governance

Nedbank Limited – R35 million fine (R15 million suspended) for failures in risk management, record keeping, cash threshold reporting and AML/CFT governance

Master Currency (Pty) Limited – R100 000 fine for failing to provide adequate and ongoing AML training to employees 

Summary of fines - SA AML Compliance breakdowns:

Summary of Anti-money laundering fines for SA 2021 - 2023

Costs of AML Compliance Failures

Beyond dramatic monetary fines, regulatory enforcement actions create massive reputational damage, loss of customer trust, and wasted resources defending penalties. Insufficient AML measures can inflict severe financial and non-financial costs.

Avoiding AML Compliance Failures

The analysis of major UK and South African AML penalties identifies consistent weaknesses that firms should address:

  • Inadequate customer due diligence processes that fail to uncover ultimate beneficial ownership or fully assess customer risk
  • Deficient transaction monitoring systems that miss suspicious activity
  • Under-staffed and under-skilled AML compliance teams that cannot provide robust oversight
  • Failure to provide adequate ongoing AML training to frontline, compliance and executive staff
  • Lack of periodic audits to proactively identify control gaps

RegTech Solutions for AML Compliance

But, financial institutions can leverage regulatory technology (RegTech) to automate compliance processes and strengthen AML defences:  

  • Artificial intelligence and machine learning accurately monitor millions of transactions to detect abnormal behaviours
  • Predictive analytics instantly score customers for money laundering or sanctions risk upon onboarding
  • Identity verification solutions seamlessly validate customer identities
  • Ongoing batch screening and real-time filtering of transactions against watchlists catches bad actors
  • Advanced analytics platforms spot outliers and suspicious patterns across customer datasets

Adopting RegTech allows firms to systemise compliance, reduce headcount costs and refocus human capital on high-value oversight and control testing.

Key Takeaways and Conclusion

Robust AML measures are mandatory in today’s environment. New RegTech solutions allow the automation of tedious manual processes to drive efficiency, enhance risk monitoring, improve agility and provide audit trails for regulators to achieve AML compliance.

By investing in the right AML software and understanding past compliance failures, firms can transform processes to avoid penalties and reputational damage. 


This article is intended for educational purposes and reflects information correct at the time of publishing, which is subject to change and cannot guarantee accurate, timely or reliable information for use in future cases.

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