Daily Compliance Brief — EMEA and APAC AML Enforcement Divergence

January 14, 2026

Signal

New data from global enforcement reporting shows that total financial institution penalties for anti-money laundering (AML), know-your-customer (KYC), sanctions and customer due diligence (CDD) violations declined overall in 2025 compared with 2024, falling by roughly 18 percent. This broad-based decline masks significant regional disparities: enforcement actions in Europe, the Middle East and Africa (EMEA) and in Asia-Pacific (APAC) increased markedly, while North American penalty volumes and counts contracted substantially.

In EMEA, concluded investigations drove a large portion of the regional increase in fines, with key actions concluding in late 2025. APAC also saw elevated enforcement activity across banking and non-bank sectors. By contrast, the United States recorded a sizeable reduction in both the number and total value of AML-related penalties, despite remaining one of the largest individual markets for enforcement when aggregated. The digital assets sector continued to represent a significant share of enforcement penalties where activity persisted.

Why it matters

For compliance teams, this divergence signals a shifting global enforcement landscape where regional regulators are prioritising the conclusion of protracted AML compliance probes and imposing significant penalties, even as other markets show enforcement contraction. Firms operating in or with counterparties in EMEA and APAC should reassess risk-based monitoring frameworks, ensuring controls for KYC, transaction monitoring and sanctions screening are fully aligned with heightened supervisory expectations in those jurisdictions.

The reduction in North American enforcement activity does not diminish overall risk exposure; institutions should continue to maintain robust governance and documentation practices given the persistence of high-value penalties in key sectors, especially for digital assets and sanctions non-compliance. The regional enforcement patterns observed for 2025 highlight the importance of differentiated compliance strategies tailored to evolving regulatory priorities.