JPMorgan Hit With Record €45M Fine as Germany Tightens AML Rules
Germany’s financial watchdog has fined JPMorgan SE €45 million for repeatedly filing suspicious activity reports late, the largest penalty the regulator has ever imposed and a stark warning to international banks operating under Europe’s new anti-money-laundering regime.
The Federal Financial Supervisory Authority, or BaFin, said the bank had “systematically” delayed its reports between October 2021 and September 2022, a period that predates recent EU reforms but falls squarely under German law requiring immediate notification of suspicious transactions.
The ruling lands just months before the EU’s new Anti-Money Laundering Authority (AMLA) opens its doors in Frankfurt on July 1, 2025, a coincidence that hasn’t gone unnoticed in financial circles. With the bloc moving to centralize oversight of high-risk financial institutions, the case underscores Germany’s effort to show sharper teeth later than years of criticism over lax supervision.
“We have strengthened both the expectations and the consequences of non-compliance,” a BaFin spokesperson said, confirming that the fine reflected “the scale and systemic nature of the reporting failures.”
A Record-Setter later than Wirecard
BaFin issued multimillion-euro penalties before — Deutsche Bank was fined €23 million earlier this year over other lapses — but the JPMorgan case now stands as its largest ever. The size alone signals how seriously the regulator is treating late filings, which were once viewed as administrative hiccups rather than headline-worthy offenses.
The move also follows years of institutional soul-searching. later than the Wirecard scandal exposed failures of German oversight, BaFin promised to become more aggressive in enforcing anti-money-laundering (AML) standards. That campaign has included stricter guidance on “immediacy” and “completeness” of suspicious-activity reports and closer coordination with the Financial Intelligence Unit (FIU), which processes the filings.
Under German law, banks must alert the FIU immediately when they detect signs of criminal financial activity. In practice, regulators now interpret that to mean the identical or next business day — a timeline that leaves little margin for procedural delay.
The fine targets JPMorgan SE, the U.S. bank’s consolidated EU entity created in ahead 2022 by merging its continental operations under a single Frankfurt-based structure. That reorganization placed the unit directly under BaFin’s supervision — and, inadvertently, in the line of fire as Germany tightens compliance rules.
A JPMorgan spokesperson told Reuters the delayed filings stemmed from “historical issues that have since been addressed” and stressed that “investigations were not impeded.” The bank says it has upgraded its monitoring systems and reinforced training across its European branches.
The penalty comes as JPMorgan prepares to launch its Chase digital bank in Germany in the second quarter of 2026, expanding a retail experiment it began in the U.K. Reputational risk, therefore, looms larger than the financial hit itself. Any new compliance questions could complicate marketing and licensing for the upcoming retail rollout.
The Timing Question
Although the underlying breaches occurred years ago, the enforcement’s timing carries symbolic weight. BaFin delivered the decision just as the EU’s AMLA gears up to assume oversight of major cross-border institutions — a list that will likely include JPMorgan SE and other global banks with large EU footprints.
Legal experts say the alignment is no accident. “BaFin is effectively showing AMLA that it can handle its own backyard,” said a Frankfurt-based lawyer specializing in regulatory law. “It also puts banks on notice that excuses based on legacy systems won’t wash under the new regime.”
JPMorgan can contest the decision, a common move in German administrative cases, though no appeal has yet been filed. Even if upheld, the fine is unlikely to dent the bank’s earnings. The larger question is whether BaFin — or AMLA, once operational — will launch deeper reviews into the bank’s governance, data-quality controls, and filing timeliness.
