Welcome to About AML midweek brief on enforcement cases
Prosecutors are looking into alleged AML failures at one of the world's biggest fintechs, sanctions have reached both crypto exchanges, and regulators are still finding banks struggling with some of the most basic AML requirements.
Let’s break down what happened and what it means
The Wise investigation: what we know so far
The Brussels Public Prosecutor’s Office is at an advanced stage in its investigation of Wise Europe, the European arm of the London-listed money transfer giant Wise.
About €500 million in suspicious transactions are reportedly under review, with the investigation covering more than 30 European countries.
What makes this case interesting is how it started.
It wasn’t one suspicious transaction that caught investigators’ attention. According to reports, Wise accounts kept appearing again and again across hundreds of unrelated criminal files in Belgium. Like Fraud cases, drug trafficking investigations, corruption probes, different crimes, but the same company name showing up in all of them.
Which would of course raise suspicion
Prosecutors are now reportedly preparing what is known as a direct summons, a Belgian legal procedure that can send a case straight to criminal court.
This is also the third major regulatory action linked to Wise’s AML controls in the last three years. There was a Belgian remediation plan in 2021, another in 2024, and a $4.2 million penalty from US state regulators in 2025.
One question is:
did Wise properly identify its customers and understand what they were doing?
No matter how advanced technology becomes, AML often comes back to the basics.
📌 Full Wise deep dive coming in About AML soon.
Denmark seeks a record €880M fine against Nordea
Danish prosecutors have asked a court to impose a 6.6 billion Danish krone (€880 million) penalty on Nordea.
The case relates to alleged AML failures between 2012 and 2015, with around €3.5 billion in suspicious transactions linked to the period under review.
What to note about this case
First, the amount.
If approved, this would be the largest AML penalty ever imposed in Denmark and one of the largest in the Nordic region.
Second, the time gap
The conduct under review happened more than a decade ago.
That’s important to note that AML failures can have a very long tail. Banks thought they had moved past their compliance issue but doesn’t mean regulators or prosecutors have moved on.
The court will now decide whether the requested penalty should be granted.
HSBC Swiss unit under formal investigation in France
France’s financial crime prosecutor (PNF) has placed HSBC’s Swiss subsidiary, Banque HSBC Suisse, under formal judicial investigation.
The case is linked to allegations involving the former governor of Banque du Liban (Lebanon’s central bank), who is accused of embezzelent of over $300 million in public funds.
HSBC’s Swiss unit is being investigated for:
Conspiracy to embezzelment of public funds
Breach of trust
Bribery of a public official
French prosecutors are looking at whether a major private banking hub may have helped move suspected public money linked to a politically exposed person (PEP) out of Lebanon.
in France, a “formal investigation” (mise en examen) means prosecutors believe there is serious enough evidence to investigate further, but it is not a finding of guilt.
It’s not just about individuals anymore, but whether a financial institution may have enabled the flow of funds.
US sanctions four Iranian crypto exchanges
The US Treasury has sanctioned four major Iranian cryptocurrency exchanges: Nobitex, Wallex, Bitpin and Ramzinex.
The exchanges are accused of supporting sanctions evasion, terrorism financing and regime-linked transactions.
These exchanges are accused of helping move money around international sanctions restrictions.
These exchanges are now on the US sanctions list, meaning US persons are prohibited from dealing with them, and firms globally need to understand whether they have any direct or indirect exposure.
Hungary seizes £223 million in central bank foundation probe
Hungarian prosecutors and police have seized approximately 92 billion Hungarian forints (€263 million) in funds and securities as part of a money laundering investigation involving foundations established by the National Bank of Hungary.
Investigators are looking at whether money moved through a web of investment structures linked to these foundations and whether public assets were managed appropriately.
Political exposure doesn’t always come through an individual customer.
Sometimes it sits inside foundations, trusts, charities or other organisations connected to powerful institutions.
Those structures can appear legitimate, but they can also create layers that make oversight more difficult.
FINMA warns Swiss banks of persistent AML risk analysis gaps
The Swiss Financial Market Supervisory Authority (FINMA) reviewed the AML risk assessments of more than 30 banks and financial institutions since issuing guidance in 2023.
The good news? Things have improved.
The bad news? Regulators are still finding weaknesses in the same areas.
Some of the areas include
• Risks linked to politically exposed persons (PEPs)
• Risks linked to complex ownership and corporate structures
• Risks linked to crypto-related services
For anyone working in AML, this is a list of areas regulators are paying close attention to.
And if you’re not in Switzerland, don’t assume this only applies to Swiss firms. These are the same areas supervisors are focusing on globally.
What’s important to know?
AML enforcement is becoming broader because scrutiny is no longer limited to banks.
This week’s stories involved a fintech, crypto exchanges, a central bank foundation, and traditional financial institutions.
It’s becoming deeper because authorities are increasingly moving beyond administrative penalties and looking at criminal investigations. The Wise case is becoming a criminal court case, Nordea faces a record fine attempt, Hungarian prosecutors seized assets before charging.
In AML understanding the basics matter
Customer due diligence.
Understanding ownership structures.
Transaction monitoring.
Sanctions screening.
For early careers learning AML and businesses anvigating AML obligations, don’t wait for regulators to spot patterns in your customer base before you do.
Official sources
The Bureau of Investigative Journalism — Wise Dirty Payments investigation
Hungary seizes £223 million in central bank foundation probe
The Wise deep dive lands in About AML next Monday, including the timeline, the regulatory history, and what AML compliance teams should be looking out for.
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