Shortcomings in Money Laundering Prevention Lead to €45 Million Fine for J.P. Morgan

Key Takeaways

• €45M Fine Issued: BaFin imposed a €45 million administrative fine on J.P. Morgan SE for shortcomings in money laundering prevention.
• Systemic Reporting Failures: Between October 2021 and September 2022, the bank repeatedly failed to file suspicious transaction reports without delay.
• Breach of Supervisory Obligations: BaFin found the bank culpably breached internal control requirements under Germany’s Money Laundering Act.
• Turnover-Based Penalty: Systematic AML control failures can result in fines tied to an institution’s total turnover, contributing to the high penalty amount in this case.

Deep Dive

Germany’s financial watchdog has fined J.P. Morgan €45 million after identifying widespread failures in the bank’s processes for reporting suspicious transactions, according to a notice from the Federal Financial Supervisory Authority (BaFin).

The Frankfurt-based institution was found to have “culpably breached” its supervisory obligations related to internal controls designed to detect and report potential money laundering. BaFin said that, between October 4, 2021, and September 30, 2022, the bank systematically failed to submit suspicious transaction reports to the German Financial Intelligence Unit (FIU) without undue delay, a core requirement under Germany’s Money Laundering Act (Geldwäschegesetz).

The enforcement action became final on October 30, 2025.

Under the Money Laundering Act, banks and other credit institutions are required to maintain effective internal systems to prevent illicit financial activity and must promptly flag transactions that appear linked to money laundering or terrorist financing. Timely reporting allows the FIU to evaluate the activity and, when necessary, forward intelligence to law enforcement agencies.

BaFin noted that when such failures occur on a systemic scale, fines may be calculated based on an institution’s total turnover. This mechanism can lead to penalties in the tens of millions of euros, as seen in this case.

J.P. Morgan has not issued a public statement in response to the fine.

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