The AML Credibility Crisis: If Major Banks Can’t Get It Right, Who Can?

Major AML failures at large financial institutions matter well beyond the banking sector. They undermine the credibility of the entire “gatekeeper” model that regulators depend on and nowhere is that more consequential than in property. 

When conveyancers are expected to conduct rigorous customer due diligence, verify beneficial ownership, scrutinise source of funds, and escalate suspicion under intense completion pressure, they operate within a system that is supposed to set the standard from the top. Recent enforcement action shows that standard is still being missed too often.

Recent Enforcement: The Pattern Is Clear

The 28 January 2026 raids on Deutsche Bank’s offices in Frankfurt and Berlin are the latest example. German prosecutors described an investigation involving “unknown individuals and employees” and the bank’s historic relationships with foreign companies suspected of facilitating money laundering. Deutsche Bank confirmed the searches and said it was cooperating. Even without presuming any outcome, a raid of that scale sends a reputational shockwave, it signals that serious AML questions can persist or re-emerge inside institutions with extensive compliance infrastructures.

Germany has also demonstrated that even procedural “fundamentals” still fail in practice, sometimes in ways regulators view as systemic. In November 2025, BaFin imposed a €45 million administrative fine on J.P. Morgan SE for shortcomings that meant it systematically failed to submit suspicious transaction reports “without undue delay” between October 2021 and September 2022. For anyone in property compliance, the message is stark.  Timely suspicion reporting is not a technicality. It is treated as a core control, and major institutions still get it wrong.

In the US, recent AML resolutions have been even more explicit. TD Bank pleaded guilty in October 2024 to offences including conspiracy to fail to maintain a compliant AML program and related reporting failures, as part of coordinated criminal and civil outcomes. Penalties totaled $3.1 billion in combined resolutions, a clear signal that regulators will treat prolonged control weaknesses as an enterprise-level failure, not isolated lapses.

In the UK, the enforcement pattern reinforces the same point.  Growth, operational strain, and weak controls are not acceptable defences. In December 2025, the FCA fined Nationwide £44 million for inadequate anti-financial crime systems over a multi-year period. That same month, Metro Bank was fined £16.7 million for transaction monitoring failures affecting over 60 million transactions worth more than £51 billion. In 2024–2025, the FCA imposed major penalties on challenger banks including Starling (£28.96m) and Monzo (£21.09m) for financial crime control failings.

Why This Matters for Conveyancing

This matters for conveyancing AML checks because it erodes the “tone from the top” that sustains compliance culture across sectors. Conveyancers are asked to act as a critical control point, preventing illicit funds from being converted into property, yet they typically operate with point-in-time information, limited transaction visibility beyond what the client provides, and intense commercial time pressure. When repeated high-profile banking failures show that even continuous monitoring environments can miss red flags, file late reports, or operate with control gaps for years, it becomes harder to treat property AML as a shared, credible mission rather than a compliance burden.

It also creates a practical risk.  Criminals adapt. If they perceive bank controls as inconsistent or enforcement as periodic rather than persistent they will continue to push value into property through complexity, layered corporate structures, nominees, third-party payments, offshore links. They exploit urgency, compressing timescales to reduce scrutiny. In that environment, conveyancing AML is only effective if it is genuinely risk-based and evidence-led.  Beneficial ownership must be verified, source-of-funds narratives independently corroborated where risk is elevated, and escalation treated as a normal outcome of risk management, not an exceptional “deal killer.”

The Professional Response

The conclusion is not that conveyancing AML is futile. It is that major AML failures at the top of the system raise the standard required at the property boundary. They erode confidence, distort incentives, and invite skepticism about whether the system truly rewards robust controls.