Cases
While money laundering dominates headlines in financial crime, Anti-Financial Crime (AFC) is a broader discipline that encompasses sanctions evasion, bribery and corruption, fraud, market abuse, insider trading, and terrorism financing. Some of the most instructive and damaging failures in recent years have occurred outside the AML space — and yet, many institutions failed to identify the gaps until too late.
Here are four high-profile AFC failures that changed the way regulators and organizations approach non-AML risk.








⚠️ 1. Ericsson Bribery & Corruption Scandal (Anti-Bribery & Corruption)
Year(s): 2000–2016, Investigated 2013–2019
Jurisdiction: Global (U.S. DOJ/SEC, Sweden, Iraq, China, Djibouti, Indonesia, Kuwait)
Penalty: $1.06 billion settlement with U.S. DOJ & SEC
📌 What Happened:
Telecom giant Ericsson admitted to systemic bribery of government officials across multiple countries, disguising payments as “consulting fees” and using slush funds to secure contracts. Despite internal compliance structures, middle management circumvented controls, and whistleblowers were ignored for years.
🧠 Key AFC Lessons:
ABC risk cannot be outsourced — “third parties” are a major exposure point
Internal audit and compliance must be independent, empowered, and heard
Cultural tolerance of “commercial shortcuts” can enable years of misconduct
⚠️ 2. Glencore Market Manipulation & Bribery Case (Market Abuse + Corruption)
Year(s): 2007–2018
Jurisdiction: U.S., UK, Brazil, Nigeria, Democratic Republic of Congo
Penalty: Over $1.5 billion in fines (U.S. DOJ, UK SFO, Brazilian authorities)
📌 What Happened:
Glencore, a multinational commodity trading firm, engaged in bribery of public officials, price fixing, and fuel market manipulation in several emerging markets. Executives used coded emails, physical cash deliveries, and fake consulting invoices to conceal corruption. Several traders pled guilty.
🧠 Key AFC Lessons:
Market abuse overlaps with bribery and corruption in opaque sectors (like oil, mining, and commodities)
AFC controls must extend to physical supply chains, not just financial systems
Front office employees (traders, salespeople) require focused AFC oversight
⚠️ 3. Standard Chartered Sanctions Violations Case (Sanctions Compliance)
Year(s): 2007–2013
Jurisdiction: U.S. (DOJ, OFAC, NYDFS, FCA)
Penalty: Over $1.1 billion in fines
📌 What Happened:
Standard Chartered processed thousands of wire transfers on behalf of Iranian, Sudanese, Syrian, and Cuban entities, using stripped or masked SWIFT data to avoid triggering U.S. sanctions filters. Some employees actively coached clients on evasion tactics. The violations occurred despite internal awareness of the risk.
🧠 Key AFC Lessons:
Sanctions compliance is not just name screening — it requires deep transactional scrutiny
Deliberate evasion of controls, even by a minority of employees, can cause organizational-wide exposure
Regulatory tolerance for repeat offenses is zero — SC had already settled once for similar misconduct
⚠️ 4. Wirecard Fraud & Misreporting Scandal (Corporate Fraud / Internal Controls)
Year(s): 2008–2020
Jurisdiction: Germany, Philippines, global payment networks
Penalty: Corporate collapse; criminal charges against CEO and other executives
📌 What Happened:
Wirecard, once considered Europe’s fintech darling, fabricated €1.9 billion in revenue via non-existent third-party partners in Asia. The fraud was enabled by fake audits, false balance confirmations, and weak regulatory oversight. Internal controls and compliance teams were sidelined or manipulated.
🧠 Key AFC Lessons:
Corporate fraud can occur at the executive level — and AFC programs must monitor internal actors, not just customers
Auditors, board members, and regulators failed to detect multiple red flags
Payment platforms and fintechs are vulnerable to weak internal segregation of duties and control overrides
🧭 Final Takeaway: AFC Is Not Just About Dirty Money — It’s About Misused Power
These four cases show that AFC risks:
Infiltrate every business line (from front office to third parties)
Exploit blind spots in governance and culture
Evolve faster than policies can be rewritten
Organizations must build a comprehensive AFC framework — not just for AML, but for ABC, sanctions, fraud, and internal misconduct.
And the best defense? Empowered compliance teams, robust training, role-specific escalation processes, and a culture that refuses to look the other way.


Contact us
amltraining@zoho.com
© 2025. All rights reserved.