The case is significant not only because it produced FinCEN’s largest-ever BSA penalty against a broker-dealer, but because it shows how unresolved compliance failures can become far more costly when they persist after a prior enforcement action. The record penalty also arrives at a moment of leadership change: FinCEN Director Andrea Gacki, who framed the UBS action as a warning to recidivist institutions, is leaving the agency to become Citigroup’s head of sanctions.
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