Zenoo Compliance Brief
Nasdaq: $206bn annual AML spend fails to stem $3trn illicit flows
Plus, State Street hit with $7.5m OFAC fine, FINMA penalises Mirabaud $15m, and OFAC warns on Iran sanctions risks in Strait of Hormuz.
9 February 2026 · 4 min read
The numbers are brutal. Financial crime programmes consumed $206 billion globally last year, yet regulators counted $3 trillion in illicit funds moving through the system. Transaction monitoring failures dominated enforcement actions worth $4.5 billion in fines across 2024. Today we break down Nasdaq's annual report, plus three fresh enforcement cases that show where the gaps still sit: sanctions compliance at major custodians, onboarding failures at private banks, and emerging geographic risks you need on your radar.
In today's brief
- 1 Why $4.5bn in 2024 fines suggests transaction monitoring remains the weakest link in financial crime defence
- 2 How did custodial data operations become the weak link in sanctions compliance?
- 3 What did Mirabaud's AML failures reveal about private banking compliance oversight in Switzerland?
- 4 How should compliance teams screen Hormuz-linked shipping transactions under new OFAC guidance?
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