FinCEN assesses $125 million penalty against UBS Financial Services Inc. for recidivist Bank Secrecy Act violations

On 3 August 2026 the Financial Crimes Enforcement Network (FinCEN) issued a consent order assessing a $125 million civil money penalty against UBS Financial Services Inc. (UBSFS), which FinCEN described as the largest it has imposed on a broker-dealer for Bank Secrecy Act violations. FinCEN found that UBSFS willfully failed to maintain an adequate anti-money-laundering programme and to file suspicious activity reports, having left more than 61,500 foreign-currency wires with an aggregate value above $10.5 billion outside effective monitoring between January 2019 and June 2023. UBSFS admitted to the statement of facts and to the willful violations, and waived its rights to judicial review and appeal.

The order is FinCEN’s second against the firm. In December 2018 UBSFS settled an earlier BSA matter for $14.5 million over the same category of failure — inadequate monitoring of foreign-currency wires — and told FinCEN it expected to remediate by mid-2019. Per the order, a replacement automated monitoring system was not deployed until March 2021, its implementation was flawed, and UBSFS did not disclose the continuing gap until FinCEN’s investigation was already under way; FinCEN’s enforcement factors label the firm a recidivist. The part that carries this beyond a large fine is the repetition on identical ground: a monitoring obligation that a prior settlement recorded but did not, in practice, compel.

The resolution mandates an independent lookback and an AML-programme review that must prioritise four “priority illicit finance risks” FinCEN named: the U.S. Southwest border and cartels, Iran, Venezuela and Russia. The statement of facts sets out customer-due-diligence failures on relationships with ties to Russia and Latin America, including accounts the order links to OFAC-designated Russian figures and to reporting on the Troika Laundromat. The headline number is layered: FinCEN credited $48 million of the $125 million against parallel penalties UBSFS agreed to pay FINRA ($20m), the SEC ($20m) and the CFTC ($8m), leaving $62 million payable to the Treasury now and a further $15 million due by May 2028 that FinCEN may waive against qualifying remediation costs. What the order does not establish is where the unmonitored money went: the four named risks scope the review to come, not a finding on the destination of the wires.