The US Treasury’s Financial Crimes Enforcement Network has ordered UBS Financial Services to pay a civil penalty of $125 million, which it called the largest it has ever imposed on a broker dealer for violations of the Bank Secrecy Act. UBS admitted that it had willfully violated that Act, the law that requires financial firms to maintain controls against money laundering. On the same day, the Financial Industry Regulatory Authority fined the firm a further $20 million for related failures.
In its enforcement action on 3 August 2026, FinCEN said UBS had left more than 50,000 foreign currency wires, worth over $10 billion in total, without adequate monitoring because of weaknesses in its automated systems, and that the firm had failed to run an anti money laundering programme meeting the minimum requirements of the Bank Secrecy Act.
What UBS failed to catch
The gaps went beyond a single broken control. FinCEN found that UBS did not properly monitor high risk customers with ties to Russia and Latin America, did not adequately weigh the money laundering risk posed by where those customers’ wealth came from, and ignored negative news reports alleging links to corruption, fraud and money laundering. It also failed to file hundreds of suspicious activity reports on time.
FINRA, which examined the same conduct, put the period at January 2019 to June 2023 and the volume even higher, at more than 60,000 foreign currency wires. For much of that time the firm relied on a manual process that reviewed thousands of wires by hand each quarter. An automated tool it introduced in February 2021 was no fix: FINRA found it simply omitted about a third of the foreign currency wires flowing through retail accounts.
A repeat offender
What drew a penalty of this size was not only the conduct but its history. Both regulators framed UBS as a repeat violator. In a coordinated December 2018 action, FinCEN had already assessed a $14.5 million penalty against the firm and FINRA fined it $4.5 million, over much the same failure to monitor foreign currency wires. UBS did not remediate the problem.
“Today’s historic action against UBSFS should send a clear message that recidivist financial institutions will face severe repercussions,” said FinCEN Director Andrea Gacki. “Repeat violators of the Bank Secrecy Act jeopardize the integrity of our financial system, especially those that expose it to high-risk customers and activities without effective controls.”
What UBS must now do
Under its consent order with FinCEN, UBS must commission a third party lookback to find suspicious transactions it never reported, and an independent review of its anti money laundering programme focused on the US south west border and cartel and narcotics activity, Iran, Russia and Venezuela. If it completes that work and adopts the recommendations, FinCEN will waive up to $15 million of the cost. Neither agency said the $20 million FINRA fine would be credited against the $125 million.
Why it matters
For compliance teams the message is less about the headline number than about what earned it. A firm that had already been penalised for weak wire monitoring, and told to fix it, was penalised again years later for the same weakness, at nearly nine times the earlier cost. Regulators are treating unremediated findings as an aggravating factor in their own right.
“This action underscores FINRA’s approach to progressive discipline, which includes escalating sanctions for recidivist misconduct,” said Bill St. Louis, the regulator’s head of enforcement. The practical lesson for broker dealers is that automated monitoring is only as good as its coverage, that customer due diligence has to account for a client’s source of wealth and adverse media, and that a remediation promise made to a regulator is one the same regulator will come back to check.
