American regulators collected 61% less in money laundering and sanctions breach fines in 2025 compared to 2024, marking a significant policy pivot under President Donald Trump’s second term. This drop, from $4.3 billion to approximately $1.7 billion, contrasts with surging global enforcement and prompts analysis of enforcement trends, political influences, and broader economic ramifications. Detailed examination reveals a deliberate retreat from aggressive policing, reshaping compliance landscapes for financial institutions.
Enforcement decline of the sanctions
The sharp reduction in US fines for anti-money laundering (AML) and sanctions violations in 2025 underscores a transformative shift in regulatory priorities. According to reports from compliance trackers like Fenergo, US penalties in these categories plummeted to $1.7 billion by late December, a 61% decrease from the $4.3 billion imposed in 2024.
This figure encompasses actions by key agencies including the Department of Justice (DOJ), Financial Crimes Enforcement Network (FinCEN), Office of Foreign Assets Control (OFAC), Securities and Exchange Commission (SEC), and Commodity Futures Trading Commission (CFTC). While 2024 saw relentless pursuit of banks and crypto firms, 2025’s tally reflects fewer high-profile cases, with the largest being Credit Suisse’s $511 million settlement for facilitating tax evasion schemes linked to AML lapses.
Early-year momentum, such as DOJ’s $504 million against crypto exchange OKX for sanctions breaches, gave way to a noticeable slowdown post-spring, aligning with administrative directives. Experts attribute this not to diminished illicit activity but to prosecutorial discretion favoring de-escalation, potentially signaling to global actors a softer US stance on financial crimes. The disparity is stark when segmented: AML fines alone dropped amid paused investigations, while sanctions enforcement, historically robust, saw sporadic large penalties but overall contraction.
Historical context
To grasp 2025’s anomaly, one must contextualize it against prior years’ escalation. In 2024, US regulators dominated globally, levying $4.3 billion in financial penalties, of which over 80% targeted banks for AML and monitoring failures. This built on 2023’s trajectory, where fines exceeded $5 billion cumulatively, driven by mega-settlements like Binance’s $4.3 billion AML/sanctions resolution, the largest ever.
The Biden-era “whole-of-government” approach amplified coordination, with OFAC alone issuing $1.2 billion in 2024 sanctions fines, focusing on Russia, Iran, and China evasion networks. Crypto emerged as a hotspot, absorbing $756 million in US penalties that year, nearly the global total. Such vigor stemmed from post-FTX scandals and geopolitical tensions, compelling firms to invest billions in compliance tech. By contrast, pre-2021 Trump years saw fluctuating but generally lower enforcement, averaging under $2 billion annually, suggesting 2025’s drop reverts to a familiar pattern interrupted by interim aggressiveness.
Key 2025 cases
Despite the overall decline, select 2025 enforcements highlight persistent hotspots, albeit fewer in number. Credit Suisse’s $511 million penalty dominated, resolving probes into undeclared Swiss accounts aiding money laundering for US clients. In crypto, the DOJ and FinCEN hit OKX with $504 million in February for willful sanctions violations involving sanctioned entities, marking one of the year’s largest. BitMEX faced over $100 million from CFTC and FinCEN for AML program deficiencies enabling darknet trades.
Traditional banking saw OFAC’s $216 million against GVA Capital in June for processing Iran-related payments, and DOJ’s $150 million on a major US bank for Russia sanctions lapses. These 19 major actions pale against 2024’s volume, with no billion-dollar deals materializing. Mid-year reports noted OFAC’s civil penalties totaling under $500 million by July, a fraction of prior paces. Such cases, while punitive, indicate selective targeting prioritizing egregious national security threats over routine compliance slips.
Political drivers
President Trump’s reelection and January 20, 2025, inauguration catalyzed the enforcement retreat, fulfilling campaign pledges for deregulation. Executive orders within weeks directed agencies to review “burdensome” rules, explicitly pausing AML probes deemed overly aggressive. FinCEN delayed the Investment Adviser AML rule from 2026 to 2028, citing resource reallocation. DOJ memos under new leadership emphasized “smart on crime,” deprioritizing corporate fines in favor of individual prosecutions tied to terrorism or drugs.
Trump’s appointees, including OFAC head Andrea Gacki, signaled continuity on core sanctions but leniency for inadvertent breaches by allies. This echoes first-term patterns, where fines dipped amid tariff-focused trade wars. Critics, including former regulators, warn of vulnerability to Russian and Chinese laundering, but proponents hail relief for overcompliant firms. Geopolitically, it complements Trump’s deal-making diplomacy, potentially easing secondary sanctions on European banks.
Global comparisons
While US fines waned, global AML/sanctions penalties exploded, exposing America’s outlier status. Fenergo reported H1 2025 worldwide fines at $1.23 billion, a 417% surge with EMEA up 147% to $168.2 million and APAC rising sharply. UK’s FCA issued £179-186 million, tripling prior individual penalties for weak controls. EU regulators, via BaFin and AMF, hit €500 million, targeting Danske Bank remnants. Sanctions globally jumped from $3.7 million H1 2024 to $228.8 million, led by EU probes into Russia evasion. Crypto fines topped $1 billion worldwide, with Singapore and Dubai aggressive where the US softened. This divergence pressures US firms operating abroad, risking dual-compliance costs, and elevates non-US hubs like Dubai for illicit finance.
The 61% fine reduction portends enduring shifts in compliance economics and illicit finance risks. Financial institutions, having spent $10+ billion annually on AML post-2024, now anticipate savings but heightened vigilance for targeted risks. Reduced deterrence could inflate laundering volumes, estimated at 2-5% of GDP globally, undermining US sanctions efficacy against adversaries.
For crypto, early fines signal no full amnesty, but lighter touch may spur innovation under Trump’s pro-blockchain stance. Internationally, allies like the UK/EU may fill voids, fragmenting standards and complicating multinational ops. Policymakers face trade-offs: deregulation boosts growth (projected 0.5% GDP lift), but at potential security cost. Long-term, 2026 data will test if pauses yield resurgence or entrench leniency, with Congress eyeing oversight reforms.