The ability, by competent authorities, to impose administrative sanctions and other corrective measures to hold firms liable for breaches of their AML/CFT obligations is one of the cornerstones of an effective AML/CFT regime. To be effective, administrative sanctions or measures should be proportionate to the breach and the nature and size of the firm, and dissuasive to change the firm's behaviour and that of its peers.
The AMLD4 sets out a broad range of administrative sanctions and measures all Member States must be able to impose for breaches of the applicable AML/CFT framework. It also requires that competent authorities publish information on the sanctions and measures they have imposed. This is because publishing information can have an important deterrent effect, and is also relevant for:
Listed below are the links to the competent authorities' websites that contain information on sanctions and administrative measures they have imposed for breaches of applicable AML/CFT obligations.
Pursuant to Article 60 of Directive 2015/849/EU, Member States are required to ensure that a decision imposing an administrative sanction or measure for breach of the national provisions transposing the Directive against which there is no appeal shall be published by the competent authorities on their official website immediately after the person sanctioned is informed of that decision. The publication shall include at least information on the type and nature of the breach and the identity of the persons responsible. Member States shall not be obliged to publish decisions imposing measures that are of an investigatory nature.
In accordance with Article 62(3) of Directive 2015/849/EU, the ESAs shall maintain a website with links to each competent authority's publication of administrative penalties under Article 60. Set out below are the relevant links provided by the competent authorities responsible for the adoption of administrative sanctions and measures in each Member State when the AML legislation is breached.
Name of the authority / authorities
Autorité des services et marchés financiers (NL)
Banque nationale de Belgique (FR)
Financial Supervision Commission Bulgaria (EN)
Danish Financial Supervisory Authority (DK)
Danish Financial Supervisory Authority (EN)-decisions
Danish Financial Supervisory Authority (EN)-orders
The Regional State Administrative Agency for Southern Finland
Malta Financial Services Authority (MFSA)
Comissão do Mercado de Valores Mobiliários (PT) administrative sanctionsComissão do Mercado de Valores Mobiliários (EN)administrative sanctions
Comissão do Mercado de Valores Mobiliários (criminal sanctions)
Autoritatea de Supraveghere Financiară (ASF)
National Bank of Romania
Office for Money Laundering Prevention
Insurance Supervision Agency (AZN)
Comisión de Prevención del Blanqueo de Capitales e Infracciones Monetarias