Growth vs. Governance

Published on Jan 27, 2025

Recent regulatory enforcement actions against Block Inc, BitMEX and Robinhood highlight ongoing Anti-Money Laundering (AML) compliance challenges for organisations. These multi-million dollar fines show that major enforcement action from regulators looks set to continue in 2025. Each case not only reveals the severe consequences of failing to meet AML obligations but also provides valuable insights on how businesses can successfully balance rapid growth and innovation with regulatory compliance.  

Key Areas of Failure

  • Block Inc. (Cash App) 
    Block Inc, which operates the popular U.S. mobile payments service Cash App, was fined $175 million by U.S. regulators, including $120 million in consumer refunds for inadequate fraud and AML controls. Weak fraud detection allowed many unauthorised transactions to go through and fraud claims were mismanaged, with users often being denied chargebacks from their banks. Additionally, Cash App was not compliant with AML requirements which left the platform vulnerable to money laundering and terrorist financing. Cash App has stated that the failings related to an earlier compliance programme and that they have increased investment in compliance and risk management.  

  • BitMEX  
    The cryptocurrency exchange BitMEX was fined $100 million for violating the Bank Secrecy Act (BSA) by failing to implement AML and (Know-Your-Customer) KYC programmes between 2015-2020. It was found to have deliberately ignored AML laws to boost revenue. The firm had previously agreed to a $100 million fine in 2021 for inadequately screening customers. BitMEX has stated it has now become a compliant business.  

  • Robinhood 
    U.S. trading platform Robinhood Markets was fined $45 million by the (Securities and Exchange Commission (SEC). Key failings included delayed Suspicious Transactions Reports (SARs), with the SEC finding in late 2020 that they were being filed 198 days after initially being flagged. This backlog was reduced by March 2022 and the SEC noted that the AML programme did not sufficiently keep up with the fast growth of the company. Robinhood has stated these historical matters have now been resolved.  

Critical Takeaways for Financial Institutions

  1. Invest in scalable, robust AML systems 

These organisations all saw significant user growth, but did not sufficiently invest in scalable compliance programmes that could keep up with the rate of new users. Compliance should not be an afterthought and it is vital to invest in automated technology solutions such as KYC360 to ensure that systems can sufficiently handle increasing transaction volumes.  

  1. Prompt reporting is critical 

Delayed SAR filings expose firms to legal risks and allow potentially illicit transactions to go unaddressed. Institutions must ensure prompt reviews and filings to remain compliant. 

  1. Allocate sufficient resources 

Institutions must allocate sufficient resources to maintain robust compliance, especially when dealing with cross-border transactions and high-volume operations. Automation tools can enhance AML efficiency, but they must be complemented by skilled personnel to analyse complex cases and oversee system functionality.  

  1. Establish a strong culture of compliance 

Senior leadership must instil a robust culture of compliance throughout an organisation. Some of the key failings of these organisations can be attributed to compliance not being seen as a key priority. It is vital to foster a culture that prioritises high ethical standards and encourages cross-functional collaboration between senior leaders and compliance/risk management teams.  

Conclusion

These significant enforcement actions serve as cautionary tales for financial institutions that face the challenge of balancing innovation with compliance. By learning from these failures, organisations can better position themselves to meet regulatory expectations while maintaining consumer trust through adopting robust and scalable AML compliance frameworks.   

 

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