Encompass Corporation, a purveyor of automated intelligence programmes that run 'know your customer' checks on HNWs, recently analysed penalties related to money laundering that regulators have imposed between 2002 and April 2019. Numerous globally active banks have had to pay multi-million-dollar fines in the past year, and there is more to come.

Their research paper - which attempts to draw on all ascertainable data from around the world - shows that:

• 2019 is likely to be a year of record AML fines, overtaking 2014 (US$10.89 billion);
• US$7.7 billion of AML fines were levied between January and the end of April 2019, as opposed to $1.16 billion in same period in 2018;
• American regulators penalise institutions the most, followed by the British;
• the average fine over past 17 years is $155 million, while the median fine is $2.8 million;
• banks still have to pay the majority of penalties, but other sectors of the economy (such as gambling, legal services and crypto-currencies) are having to share more and more of the burden.

The findings show that in January, February, March and April alone, the combined value of imposed penalties was more than 70% of the total for the whole of 2014 – the year of most fines. It is nearly double the value of AML fines from the entirety of 2018 ($4.27 billion), despite the number of penalties being roughly one-third (9 in January-April 2019; 29 in 2018).

Since 2014, the total of AML penalties has remained above $1 billion every year, perhaps because of the 'Panama Papers' bandwagon onto which all governments jumped - some say in a suspiciously pre-planned and unanimous way - in 2015. Multi-million dollar fines are becoming the norm.