On August 3, 2026, FinCEN assessed a $125,000,000 civil money penalty against UBS Financial Services Inc. (UBSFS) for willful violations of the Bank Secrecy Act. According to FinCEN’s press release, this is the largest penalty ever imposed against a broker-dealer for BSA violations to date.
The action follows a 2018 Consent Order that assessed a $14.5 million civil money penalty after UBSFS failed to adequately monitor foreign currency wires. Despite assurances that the deficiencies would be remediated, UBSFS subsequently failed to appropriately monitor more than 50,000 foreign currency wires totaling over $10 billion and did not disclose the continuing issues to FinCEN. The investigation also found deficiencies in UBSFS’s customer due diligence, particularly involving high-risk customers with ties to Russia and Latin America, resulting in failures to identify and report hundreds of suspicious transactions.
Under the new Consent Order, UBSFS admits to willfully violating the BSA, including failing to maintain an adequate AML program and file required suspicious activity reports. The firm must conduct a third-party lookback to identify previously undetected suspicious transactions and undergo an independent review of its AML program, with a focus on priority illicit finance risks involving the U.S. Southwest border, cartels and narcotics trafficking, Iran, Russia, and Venezuela.
FinCEN will waive up to $15 million in related expenses if UBSFS satisfactorily completes the review and implements the third party’s recommendations.
FinCEN’s press release can be found here.
The full consent order can be found here.