Case Library

Every control failure has a name, a number and a lesson.

Regulators do not fine institutions for bad intentions. They fine them for specific, documentable control failures. These are the ones worth knowing by heart.

Denmark / Estonia

Danske Bank — Estonia Branch

Roughly €200 billion in non-resident flows passed through a single branch whose controls were never integrated into group monitoring.

Period
2007–2015
Penalty
USD 2 billion
Typology
Non-resident portfolio, correspondent banking

Malaysia / Global

1MDB

State development funds were diverted through shell companies and private banks into real estate, art and film financing.

Period
2009–2015
Penalty
USD 5.5 billion+
Typology
Sovereign fund diversion, shell layering

United States / Mexico

Wachovia

Failure to monitor USD 378 billion in transfers from Mexican currency exchange houses linked to narcotics proceeds.

Period
2004–2007
Penalty
USD 160 million
Typology
Casa de cambio, bulk cash

India

Punjab National Bank — Nirav Modi

Letters of Undertaking issued outside the core banking system funded a circular trade finance scheme for years undetected.

Period
2011–2018
Penalty
₹14,000 crore exposure
Typology
Trade finance fraud, LoU misuse

Australia

Westpac

23 million reporting breaches and undetected high-risk payment patterns to South East Asia.

Period
2013–2019
Penalty
AUD 1.3 billion
Typology
Reporting failure, child exploitation risk

United States / Mexico

HSBC — Mexico

Mexico was rated low risk despite known cartel activity, disabling the controls that should have applied.

Period
2006–2010
Penalty
USD 1.9 billion
Typology
Cartel proceeds, weak country risk rating
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