The Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN), SEC, CFTC and FINRA have imposed an aggregate $125 million in civil penalties on UBS Financial Services Inc. (UBSFS) for violations of the anti-money laundering (AML) requirements of the Bank Secrecy Act (BSA) and its implementing regulations. According to the FinCEN consent order (FinCEN Order), covering the period from January 1, 2019, through June 30, 2023, UBSFS had deficient AML policies, procedures and internal controls, which contributed to its failure to monitor tens of thousands of transactions and file suspicious activity reports when required. The penalties are particularly heavy because the firm resolved similar charges in 2018 and failed to complete promised remediation. “Today’s historic action against UBSFS should send a clear message that recidivist financial institutions will face severe repercussions,” said FinCEN Director Andrea Gacki in the press release announcing the resolution. “Repeat violators of the [BSA] jeopardize the integrity of our financial system, especially those that expose it to high-risk customers and activities without effective controls.” This article discusses the key findings in the FinCEN Order and the parallel resolutions with the SEC, CFTC and FINRA. See “Broker-Dealer to Pay $75 Million in Fines for AML Program Violations” (Jun. 18, 2026); and “FinCEN Issues First AML/CFT Priorities” (Aug. 26, 2021).