09/03/2026
What happens when an AML program looks fine on paper, but the controls fail in practice?
Practus partner, Robert Moreiro, explores that question in a new analysis of the UBS Financial Services AML settlements, following coordinated actions by four regulators on August 3.
The numbers are striking:
• $10.4+ billion across 60,000+ foreign-currency wires FINRA found were not reasonably monitored
• $125 million FinCEN penalty, its largest ever against a broker-dealer for BSA violations
But the biggest lesson isn't the size of the penalties. It's what they reveal about AML programs.
Sophisticated technology doesn't compensate for incomplete data, outdated risk ratings, disconnected compliance functions, or remediation that isn't independently validated.
And when a firm has already been warned about the same weaknesses, the stakes get even higher.
The question isn't whether your AML program exists. Can you prove it actually works?
Read Robert’s full analysis and the key takeaways for broker-dealers here: https://loom.ly/utoGEhU