FinCEN assessed a $125 million civil money penalty against UBS Financial Services Inc. (UBSFS) for willful violations of the Bank Secrecy Act. This is the largest penalty ever imposed on a broker-dealer for BSA violations. This is FinCEN's second enforcement action against UBSFS, following a 2018 Consent Order ($14.5 million penalty) for failing to monitor foreign currency wires. Despite assurances it would remediate, UBSFS continued to fail to monitor over 50,000 foreign currency wires worth more than $10 billion, and did not disclose these failures until FinCEN's own investigation uncovered them. FinCEN also found UBSFS failed to perform adequate customer due diligence on high-risk clients tied to Russia and Latin America resulting in hundreds of unreported suspicious transactions. UBSFS admitted willfully violating the BSA and must complete a third-party lookback and independent AML program review, with up to $15 million in review costs waivable upon satisfactory remediation. The review will specifically assess UBSFS's handling of illicit finance risk tied to the Southwest border/narcotics trafficking, Iran, Russia, and Venezuela.