On August 3, 2026, FinCEN published a Consent Order and combined penalty of $125 million against UBS Financial Services for recidivist and willful violations of the BSA. This historic fine, the largest to date against a broker-dealer, underscores a firm’s obligation to promptly correct material AML program deficiencies or face significant ramifications of being a repeat violator.
Despite being subject to a 2018 Consent Order for substandard AML controls, particularly regarding monitoring correspondent accounts for foreign financial institutions, and on notice to correct, UBSFS continued to ignore red flags of suspicious behavior involving foreign currency wires, and failed to implement the systems needed to mitigate risks or advise FinCEN of a delay in doing so.
Indeed, many of the same customer due diligence deficiencies and inadequate AML monitoring noted in 2018 continued long after, were numerous, and involved transactions valued at more than $10 billion.
These included among others:
- Allowing or failing to monitor transactions with customers tied to high-risk countries such as Russia or Venezuela;
- Not investigating customer’ sources of wealth or other material changes in customer information;
- Ignoring significant negative news about customers or their beneficial owners despite numerous articles about involvement in money laundering, tax evasion, or fraud schemes involving, e.g., the Russian government;
- Opening numerous accounts for shell companies across multiple branches of UBSFS involving some of the same illegal actors;
- Permitting third-party wires involving virtual assets providers or parties linked to corruption and other illegal activity;
- Failing to identify common ownership between customers prior to onboarding or investigate suspicious addresses;
- Failing to identify originators or recipients of foreign currency wires, country of origin or third-party actors;
- Filing SARs years after suspicious activity occurred including a potential 900 million pesos money laundering scheme involving UBFS accounts;
- No meaningful analysis of potential layering or pass-through activity despite alert escalations;
- A two-year delay in implementing an AML monitoring system and failing to notify FinCEN of the delay;
- Failing to address flaws in the monitoring system or institute a mechanism to govern, test or correct data mapping issues;
- Relying on manual monitoring not reasonably tailored to customer risk or which reports were not reliable or reviewed frequently enough to mitigate risk;
- Inadequate staffing to address AML monitoring;
- Management’s complicity in failing to ensure deficiencies were corrected and gaps remediated as promised.
This significant enforcement action is a stark reminder of the repercussions a firm can face if they fail to timely and effectively address AML Program failures to include substantial monetary fines, expensive external monitoring costs, and long-term damage to a firm’s reputation.
See full Consent Order here: https://www.fincen.gov/system/files/2026-07/UBS-Consent-Order.pdf