The largest fine ever imposed by BaFin on an entity was due to JP Morgan SE’s “culpable violation” of its supervisory obligations concerning internal processes for filing suspicious transaction reports.
Between October 4, 2021, and September 30, 2022, due to these procedural deficiencies, the entity systematically failed to fulfill its obligation to promptly report suspicious transactions.
The supervisor reiterates that credit institutions are required to comply with German anti-money laundering legislation and should implement adequate oversight measures to prevent violations of obligations under this law, including the “prompt” submission of suspicious transaction reports to the Financial Intelligence Unit (FIU).
“In the case of systematic violations, the amount of the administrative fine can be calculated based on the entity’s total turnover. This can lead to very high administrative fines, as in the present case,” added BaFin.
A JP Morgan spokesperson stated that “the fine relates to historical findings and the timing of the suspicious activity reports did not impede any investigations by authorities.”
The spokesperson defended the firm’s strong commitment to detecting, preventing, and reporting money laundering and financial crimes.
“We are pleased that this matter has been resolved and corrected,” the spokesperson added.
