Weekly Roundup: Regs & Risks
Increased vigilance and follow-up enforcement efforts by global governmental bodies and regulatory agencies – coupled with the efforts of financial institutions on the frontlines of the war on illicit finance – remain arguably the most vital pieces of the puzzle to stop the growth of transnational financial crime. Last week was a busy one in this regard, as multiple regulatory bodies and governmental agencies across the globe levied staunch penalties and sanctions against international banking staples, prominent cryptocurrency platforms, and terror organizations as part of their anti-money laundering and counter terrorism financing efforts.
Germany Drops Record Fine on JPMorgan
Mired in a period of financial scandals across the country, Germany’s Federal Financial Supervisory Authority (BaFin), the country’s primary financial regulatory authority, slapped JPMorgan’s Frankfurt arm with a record €45 million penalty over various shortcomings in the U.S.-based banking giant’s money laundering prevention systems. The charge comes after the subsidiary was found to have failed to adequately submit suspicious-activity reports (SARs) to the country’s Financial Intelligence Unit between October of 2021 and September of 2022, potentially leaving them susceptible to illicit financial flows. The regulator’s penalty now eclipses the previous record fine of €40 million levied against embattled Deutsche Bank in 2015.
According to the regulator, the delays in filing by the bank “culpably breached its supervisory obligations” and Germany’s Money Laundering Act as a whole, while providing criminals extra time to move their cash.2 These failures also limited the chances of apprehending those potentially dealing in illicit funds for both the regulator and law enforcement. BaFin stressed that under the Act, banks must flag potential laundering or terror-financing “without undue delay” so authorities can freeze assets or launch probes before funds vanish offshore. JPMorgan countered, stating that the delays “did not impede any investigations by the authorities” and noted that these deficiencies have already been remediated. The bank has since reportedly overhauled its internal workflows and added automated SAR triggers to prevent recurrence.
Ireland Zaps Coinbase €21.5 Million
Ireland’s Central Bank was also busy last week, as it fined an Irish subsidiary of prominent cryptocurrency exchange Coinbase Global a reported €21.5 million for breaching its anti-money laundering and counter-terrorist transaction monitoring obligations. The Irish regulator said the fine related to faults in the configuration of Coinbase Europe’s transaction monitoring system, which resulted in more than 30 million transactions slipping past the exchange’s red-flag filters over a twelve-month period. A statement issued by Coinbase representatives read that the platform inadvertently made three coding errors in its transaction monitoring system that caused five of the 21 scenarios which look for certain red flags to not fully screen all transactions in 2021 and 2022.1 The transactions that were not properly monitored were reportedly worth approximately €176 billion.
While Coinbase was able to resolve this coding issue within a matter of weeks following initial detection, the damage may have already been done, with analysts believing that a significant portion of the aforementioned financial figure was of the illicit variety. The regulator also found that it took Coinbase nearly three years to fully sort through this backlog, surfacing a total of 2,708 “suspicious” transactions linked to drugs, fraud, cybercrime and child exploitation that were reported on much later – thus limiting the effectiveness of the SAR’s.
The Central Bank of Ireland has gone on record discussing the importance of closely monitoring crypto platforms, noting that these outlets remain “especially attractive to criminals” thanks to anonymity, speed and borderless reach. For their haste in addressing the matter, Coinbase received a discounted fine of €21.5 million (reduced from €30.7 million originally) and vowed to maintain more thorough testing of their internal controls moving forward. The exchange has also rolled out enhanced code-review protocols and real-time monitoring dashboards to catch configuration drift before it snowballs.
OFAC Cuts Down Major Players in Hizballah’s Funding Pathway
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) also stayed hot in its pursuit of global terrorism orchestrators, blacklisting three Lebanese citizens who facilitated the funneling of tens of millions of dollars from Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) to Hizballah through unlicensed exchange houses since January 2025. A recent Treasury press release detailed how one of the men, Ossama Jaber personally collected tens of millions in suitcases of cash, while his counterparts Ja’far Qasir and Samer Kasbar ran oil, metals and tanker deals that openly circumvented U.S. sanctions to keep the terror pipeline open. As a result of these actions, all property and interests of the designated or blocked persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC, with all U.S. persons blocked from transacting with these individuals. Violations of these sanctions may also result in the imposition of civil or criminal penalties on U.S. and foreign persons.3
Since January of 2025, the U.S.-designated IRGC-QF has transferred over $1 billion to Hizballah, mostly through these money exchange companies. The Treasury notes that Hizballah has used these funds to support its paramilitary forces, rebuild its terrorist infrastructure, and resist the Lebanese government’s efforts to assert sovereign control over all Lebanese territory. Efforts of this variety have also harmed the integrity of the Lebanese financial system (which remains largely cash-based) given the propensity of funds derived from terrorism financing exploits to merge into legitimate financial channels. The collapse of Syria’s Assad regime in late 2024 and the death of finance chief Muhammad Qasir forced Hizballah to splinter their operations amongst new players, which has made their sprawling network harder to track. These developments have however made the regime more vulnerable to targeted sanctions, with the U.S. pushing its offensive in this manner over recent months.
Citations
- M, Muvija. “Irish Regulator Fines Coinbase Europe 21.5 Million Euros over Monitoring Failures | Reuters.” Reuters, 6 Nov. 2025.
- Oppenheim, Nadya. “Germany Fines JPMorgan €45 Million for Anti-Money-Laundering Failings.” Yahoo! Finance, Yahoo!, 6 Nov. 2025.
- “Treasury Sanctions Hizballah Operatives Exploiting Lebanon’s Cash Economy.” U.S. Department of the Treasury, 6 Nov. 2025.