Key Takeaways
- FinCEN has published 119 Bank Secrecy Act enforcement actions since 1999, and its orders impose $8.8 billion in civil money penalties.
- The largest penalty in a FinCEN order is Binance's, $3.4 billion in 2023; the ten largest are 90% of the total.
- Depository Institutions account for more actions than any other kind of institution, 48 of the 119, according to FinCEN.
- FinCEN published 15 actions in the last five years, from 2022 on.
FinCEN has published 119 Bank Secrecy Act enforcement actions since 1999, and the civil money penalties in its orders total $8.8 billion. The largest is Binance's, $3.4 billion in 2023, followed by TD Bank, N.A. and TD Bank USA's at $1.3 billion. The ten largest penalties make up 90% of the total.
FinCEN lists its actions without the amounts. Every penalty here is read from the order itself, from the sentence that imposes it, and that sentence is in the dataset beside each figure.
The 20 largest FinCEN penalties
| Rank | Date | Institution | Type | Civil money penalty | Order |
|---|---|---|---|---|---|
| 1 | November 21, 2023 | Binance Holdings Limited, et. al. d/b/a Binance and Binance.com | Money Services Businesses | $3.4 billion | FinCEN |
| 2 | October 10, 2024 | TD Bank, N.A. and TD Bank USA, N.A. | Depository Institutions | $1.3 billion | FinCEN |
| 3 | October 13, 2026 | Bank of America, N.A. | Depository Institutions | $1.2 billion | FinCEN |
| 4 | December 11, 2012 | HSBC Bank USA N.A. | Depository Institutions | $500 million | FinCEN |
| 5 | January 7, 2014 | JPMorgan Chase Bank, N.A. | Depository Institutions | $461 million | FinCEN |
| 6 | January 15, 2021 | Capital One, National Association | Depository Institutions | $390 million | FinCEN |
| 7 | February 15, 2018 | U.S. Bank National Association | Depository Institutions | $185 million | FinCEN |
| 8 | January 19, 2017 | Western Union Financial Services, Inc. | Money Services Businesses | $184 million | FinCEN |
| 9 | March 17, 2022 | USAA Federal Savings Bank | Depository Institutions | $140 million | FinCEN |
| 10 | August 3, 2026 | UBS Financial Services Inc. | Securities and Futures | $125 million | FinCEN |
| 11 | July 27, 2017 | BTC-E a/k/a Canton Business Corporation and Alexander Vinnik | Money Services Businesses | $110 million | FinCEN |
| 12 | March 17, 2010 | Wachovia Bank, National Association, Charlotte, North Carolina | Depository Institutions | $110 million | FinCEN |
| 13 | August 10, 2021 | HDR Global Trading Limited, 100x Holdings Limited, ABS Global Trading Limited, Shine Effort Inc. Limited, HDR Global Services (Bermuda) Limited, d/b/a BITMEX | Not stated | $100 million | FinCEN |
| 14 | March 6, 2026 | Canaccord Genuity LLC | Securities and Futures | $80 million | FinCEN |
| 15 | June 3, 2015 | Hong Kong Entertainment (Overseas) Investments, Ltd., d/b/a Tinian Dynasty Hotel & Casino | Casinos | $75 million | FinCEN |
| 16 | October 19, 2020 | Larry Dean Harmon d/b/a Helix | Money Services Businesses | $60 million | FinCEN |
| 17 | September 23, 2013 | TD Bank, N.A. | Depository Institutions | $38 million | FinCEN |
| 18 | January 31, 2025 | Brink’s Global Services USA, Inc. | Money Services Businesses | $37 million | FinCEN |
| 19 | August 6, 2007 | American Express Bank International and American Express Travel Related Services Company, Inc | Depository Institutions, Money Services Businesses | $25 million | FinCEN |
| 20 | May 13, 2004 | Riggs Bank, NA | Depository Institutions | $25 million | FinCEN |
Download this table (CSV), free. The full dataset, every FinCEN action with its penalty and the sentence the amount came from, is one email away.
Who FinCEN acts against
FinCEN classifies each action by the kind of financial institution involved.
| Type of institution | Actions | Penalties in the orders |
|---|---|---|
| Depository Institutions | 48 | $4.5 billion |
| Money Services Businesses | 35 | $3.8 billion |
| Casinos | 15 | $120 million |
| Not stated | 11 | $101 million |
| Securities and Futures | 7 | $242 million |
| Depository Institutions, Money Services Businesses | 2 | $25 million |
| Precious Metals/Jewelry Industry | 1 | $200,000 |
Depository Institutions account for the most actions, 48 of 119. 15 actions were published from 2022 on.
Actions by year
| Year | Actions | Penalties in the orders |
|---|---|---|
| 2026 | 3 | $1.4 billion |
| 2025 | 2 | $41 million |
| 2024 | 3 | $1.3 billion |
| 2023 | 4 | $3.4 billion |
| 2022 | 3 | $140 million |
| 2021 | 3 | $498 million |
| 2020 | 2 | $60 million |
| 2019 | 1 | $35,350 |
| 2018 | 3 | $208 million |
| 2017 | 5 | $303 million |
| 2016 | 6 | $20 million |
| 2015 | 12 | $120 million |
| 2014 | 8 | $462 million |
| 2013 | 2 | $42 million |
| 2012 | 2 | $500 million |
| 2011 | 11 | $26 million |
| 2010 | 5 | $111 million |
| 2009 | 1 | $0 |
| 2008 | 3 | $12,000 |
| 2007 | 2 | $25 million |
| 2006 | 9 | $5 million |
| 2005 | 5 | $30 million |
| 2004 | 2 | $25 million |
| 2003 | 5 | $24 million |
| 2002 | 2 | $800,000 |
| 2001 | 2 | $0 |
| 2000 | 7 | $337,500 |
| 1999 | 6 | $361,000 |
What this means for technology buyers
Most FinCEN orders describe the same failures: suspicious activity not reported, customers not identified, monitoring that did not keep up with the business. These guides compare the systems that address them:
- AML transaction monitoring for banks and fintechs: finding the activity an order says went unreported.
- KYC automation platforms: customer identification and due diligence.
- Sanctions screening software for global banks: the screening OFAC penalties turn on.
Mapping the business? The Retail Bank Business Capability Model places financial crime controls among everything else a bank runs.
More from Finantrix Atlas
How this was built
The universe is every action on FinCEN's enforcement actions page, with its date, matter number and FinCEN's classification of the institution. For each, the order was read and the civil money penalty taken from the sentence that assesses it. 91 orders state a penalty that way; the other 28 carry no amount here, because they impose none or state it in a form that could not be read without guessing.
Limits
- FinCEN only. The bank regulators and the Justice Department bring their own Bank Secrecy Act cases, often alongside FinCEN's, and their penalties are not counted here.
- Penalties as assessed. An order's penalty can be partly satisfied by payments to other agencies, so the amount paid to FinCEN can be smaller.
- Missing amounts are missing. Where an order does not state its penalty in a readable sentence, it shows none rather than an estimate.
- Replaced orders count once. Where FinCEN rescinded an order and reissued it, only the later penalty is counted.
- Names as published. Institutions are named as they stood when the action was taken.
Cite this
Free to quote, cite and republish, including the chart, with credit to Finantrix Atlas and a link to this page.
The civil money penalties in FinCEN's Bank Secrecy Act orders total $8.8 billion since 1999, and the ten largest make up 90% of it, according to a Finantrix Atlas analysis of FinCEN enforcement actions.
Suggested citation: Finantrix Atlas, "Bank Secrecy Act Enforcement: FinCEN Actions and Penalties," through October 13, 2026, from FinCEN enforcement actions. https://www.finantrix.com/articles/aml-enforcement-actions
Embed the chart:
<a href="https://www.finantrix.com/articles/aml-enforcement-actions"><img src="https://www.finantrix.com/atlas/aml-enforcement-actions.png" alt="The largest FinCEN Bank Secrecy Act penalties, from Finantrix Atlas"></a>
<p>Chart: <a href="https://www.finantrix.com/articles/aml-enforcement-actions">Finantrix Atlas</a>, from FinCEN enforcement actions.</p>
Frequently asked questions
Q: What is the largest FinCEN penalty? A: Binance's, at $3.4 billion in 2023, as stated in FinCEN's order.
Q: How many enforcement actions has FinCEN taken? A: FinCEN's enforcement page lists 119 Bank Secrecy Act actions from 1999 through October 13, 2026.
Q: What does FinCEN enforce? A: The Bank Secrecy Act, which requires financial institutions to keep records, identify customers and report suspicious activity and large cash transactions.
Download the data
The 20 rows on this page (CSV), free. The full dataset has all 119 rows, as of October 13, 2026; we email you a link.
Frequently Asked Questions
What is the largest FinCEN penalty?
Binance's, at $3.4 billion in 2023, as stated in FinCEN's order.
How many enforcement actions has FinCEN taken?
FinCEN's enforcement page lists 119 Bank Secrecy Act actions from 1999 through October 13, 2026.
What does FinCEN enforce?
The Bank Secrecy Act, which requires financial institutions to keep records, identify customers and report suspicious activity and large cash transactions.