Canada issues a record-setting fine, the UAE sharpens its financial crime clampdown, and crypto remains firmly in regulators’ sights. Lexology PRO uncovers the key AML enforcement trends in 2025 impacting businesses.
The data in this article is based on Lexology PRO’s Scanner, our automated regulatory monitoring tool covering 18 regulatory areas and tracking over 1500 regulatory sources. Full details on Scanner’s regulatory coverage can be found here.
Enforcement in this series includes any action regulators have taken as part of their enforcement powers, including active investigations, audits, decisions, fines, penalties, settlements, and/or orders. This report covers data – primarily agency announcements – released between 1 November 2024 and 1 November 2025.
Anti-money laundering (AML) enforcement activity was robust over the last 12 months, with key regulators targeting high-risk sectors and criminal networks.
Building on momentum from 2024, our data shows AML enforcement in key jurisdictions extended beyond traditional banking, with cryptocurrency operators and fintechs shouldering the brunt of regulatory action.
The Financial Transactions and Reports Analysis Centre of Canada’s (FINTRAC) record-breaking C$177 million (US$126 million) fine imposed on Xeltox Enterprises for AML violations in October 2025 underscores the scale of recent enforcement action against crypto companies – reflecting a wider crackdown on the sector in several key jurisdictions.
The US and Canada both drove major enforcement action, while the UAE continued its financial crime crackdown with numerous penalties targeting crypto exchanges.
Lexology PRO explores the AML enforcement trends demonstrated in Scanner’s data, spotlighting key enforcers, regulatory jurisdictions, and penalties.
Crypto firmly in regulators’ crosshairs
Scanner data shows the US continued to drive AML enforcement in the last 12 months, with federal and state authorities ramping up activity across both traditional and emerging high-risk sectors. Consistent with enforcement trends seen in other jurisdictions, crypto operators were first in the firing line, despite political headwinds and fragmented attempts to regulate the sector.
US authorities made headlines with major penalties. The US Department of Justice (DOJ) reached a plea deal with crypto company OKX in February 2025 for a staggering US$504 million settlement. The DOJ imposed a US$84 million fine and ordered the forfeiture of US$420 million in customer fees. Meanwhile, the New York State Department of Financial Services fined fintech company Block – owner of cryptocurrency CashApp – US$40 million in April 2025 for AML violations.
Brazil’s enforcement efforts also targeted the crypto sector, reflecting a narrowing regulatory landscape. New AML rules aimed at increasing oversight of digital assets take effect in February 2026.
Traditional banks remain in the firing line
Traditional banks also remain exposed. A penalty issued by the US Securities and Exchange Commission against Deutsche Bank in December 2024 is a reminder that legacy financial institutions face continued legal exposure.
In the UK, Barclays was handed a £39.3 million (US$52 million) fine by the UK FCA for failing to adequately manage money laundering risks related to banking services it provided to Stunt & Co.
UAE sharpens financial crime enforcement
AML enforcement also accelerated in the UAE reflecting the country’s broader financial crime crackdown. A succession of major penalties issued this year – including a 200 million dirham (US$54.4 million) fine issued in May 2025 against an unnamed currency exchange house for AML deficiencies – indicates a concerted effort to combat illicit finance and build the UAE’s reputation as a global financial hub.
AML and sanctions enforcement converge
A notable share of US AML activity also stemmed from sanctions enforcement, highlighting the growing convergence between AML and sanctions enforcement frameworks. The Office of Foreign Assets Control (OFAC) issued numerous sanctions this year linked to drug-trafficking and money laundering offences.
Canada’s enforcement surge
Canada’s FINTRAC significantly increased AML enforcement this year, issuing high-profile penalties aimed at financial institutions and crypto operators. The fine against Xeltox Enterprises mentioned above accounts for over 86% of FINTRAC’s total penalties this year – but the number of actions pursued by the regulator reached its highest level this decade. This level of activity aligns with Canada’s broader financial crime reform agenda; a new Financial Crimes Agency is expected early next year.
Financial crime enforcement in the US is fragmented across multiple federal agencies – such as the DOJ, the SEC and the Financial Crimes Enforcement Network (FinCEN). By contrast, FINTRAC operates as a single, centralised AML authority, meaning all AML penalties are consolidated under one regulator.
Other major enforcers ramp up activity
Elsewhere, the Australian Transaction Reports and Analysis Centre (AUSTRAC) clamped down on late reporting this year, issuing penalties against Revolut, Cryptolink, and Cointree.
While not among the top five regulators, Brazil’s Federal Revenue Service and the Comptroller General of the Union (CGU) rank in the top ten. Brazil’s enforcement activity is closely tied to its ABC crackdown, which escalated exponentially this year.
What can we expect from AML enforcement in 2026 and beyond?
AML enforcement will be driven by new regulatory frameworks and expanding reporting obligations in 2026.
Australia’s new AML/CTF regime takes effect in March 2026 and will increase the scope of reporting entities beyond non-financial sectors to include law firms, accounting businesses, as well as trust and company service providers – growing the number of affected organisations from 17,000 to roughly 90,000. Newly captured entities must comply by 1 July 2026.
The outlook for US AML enforcement is uncertain: changes to FinCEN’s reporting rules are unclear as stricter requirements for investment advisers intended for 2026 may be pushed to 2028.
Other indicators add further ambiguity. In October 2025, Trump pardoned the founder of crypto giant Binance, following his conviction for AML violations. Trump also called for public companies’ mandatory quarterly reporting to be scrapped in September 2025, sparking concerns among compliance professionals about reduced market transparency and integrity.
Companies in the EU should prepare for deeper scrutiny under new AML regulations. The EU AML Regulation (AMLR) and Directive (EU) 2024/1640 (AMLD6) take effect in July 2027, but certain elements of AMLD6 must be transposed by 10 July 2026, including measures to strengthen authorities’ access to beneficial-ownership information. The EU Anti-Money Laundering Authority (AMLA) – launched in July 2025 – will begin the first selection process for supervised entities in 2027.
Elsewhere, authorities in the UAE are expected to maintain a firm grip on financial crime enforcement, particularly in the crypto sector: “Virtual assets are a key area of strategic focus for the UAE, as it seeks to cement its position as a market leader in the virtual assets space,” David Berman, Dubai-based local partner at White & Case, tells Lexology PRO.