Leonteq Securities Europe Faces €35,000 Fine Amid Cross-Border AML Contradictions and Limited Transparency

BaFin recently imposed a €35,000 penalty on Leonteq Securities Europe, but unresolved contradictions across audits, supervisory investigations, public statements, and cross-border oversight have raised more questions than the fine itself. The publication accompanying the sanction offered almost no detail, a silence that sharply contrasts with the severity and breadth of findings in Germany, Switzerland, and France. Earlier regulatory findings revealed structural AML failures spanning multiple years, making the modest sanction difficult to reconcile with the record. Meanwhile, the firm had previously insisted that internal reviews showed no wrongdoing, even though a SAR was later filed and regulators in different jurisdictions reached conflicting conclusions. These layers of inconsistency have turned the Leonteq case into an emblematic example of fragmented AML oversight and selective transparency.

The first major inconsistency emerged in 2022 when Leonteq publicly responded to media allegations concerning two structured product trades executed through an offshore intermediary. The company asserted that its internal compliance team had thoroughly reviewed the transactions and found no evidence of wrongdoing. Leonteq also commissioned an external review by EY, which concluded that no suspicious activity had occurred and that no SAR was necessary. “Leonteq assured stakeholders that all required documents had been reviewed and that the intermediary had met expected standards.”

However, reporting by Les Echos indicated that a SAR was filed with Tracfin within six months of EY’s conclusion. This raised questions about whether new information had emerged after the audit or if the internal and external reviews had overlooked relevant indicators. The timing of the transactions further complicates the timeline, as the SAR appears to have been triggered by re-evaluation of existing information rather than new activity, casting doubt on the firm’s earlier claim that no suspicion existed. The Financial Times also reported concerns from former employees suggesting that oversight of specific distributors had been unreliable, adding tension to Leonteq’s narrative that all controls were functioning properly. This inconsistency became more pronounced as regulatory investigations unfolded: if internal and external reviews declared the system robust, it does not align with the weaknesses subsequently identified by regulators. The SAR timing, EY’s conclusion, and public assurances formed the foundation of the first major contradiction, which was later amplified by scrutiny in multiple countries.

Regulatory actions in Germany, Switzerland, and France exposed deeper contradictions. In 2023, BaFin issued a remediation order requiring Leonteq Europe to correct fundamental deficiencies in its AML framework. Regulators identified inadequate internal safeguards, incomplete documentation, insufficient transaction monitoring, and ineffective oversight of higher-risk relationships, noting that these failures persisted until at least the end of 2022—overlapping with the period covered by EY’s review. In Switzerland, FINMA concluded enforcement proceedings in 2024 that revealed structural deficiencies in governance, distributor oversight, and monitoring of complex transactions. FINMA required the firm to return profits associated with these relationships, emphasizing that the failures had occurred over multiple years and preceded the internal and external reviews conducted in 2022.

French authorities added another layer of contradiction. The ACPR reportedly concluded that Leonteq had access to sufficient information to detect suspicious activity, even though the firm had previously claimed it lacked adequate documentation to file a SAR. The regulator determined that the information available justified escalation and referred potential money laundering and fraud to prosecutors. This directly conflicts with Leonteq’s earlier statements, supported by EY, that all relevant information had been reviewed and no suspicion existed. Taken together, the regulatory conclusions from BaFin, FINMA, and the ACPR portray systemic failings that do not align with the company’s internal account. Conflicting statements about whether the firm had necessary documentation call into question the thoroughness and accuracy of the 2022 reviews.

The timeline of events highlights the depth of these contradictions. Allegations regarding suspicious transactions arose in late 2021 and early 2022, prompting an internal review and an external EY investigation. Both reportedly found no wrongdoing and no SAR requirement. “The company stated that all documents were available and that nothing had been identified that would justify escalation.” Yet within months of the EY report, a SAR was submitted to Tracfin, raising doubts about the completeness of the reviews. In 2023, BaFin mandated corrective measures, identifying deficiencies that should have been detected during the EY audit, including missing safeguards, incomplete documentation, and ineffective monitoring. FINMA’s 2024 findings on governance and distributor oversight similarly contradicted assertions that controls were effective in 2022.

When BaFin issued the €35,000 fine in 2025, the accompanying disclosure provided almost no detail about the breach, leaving unclear whether it related to incomplete remediation, new failures, or other concerns. The modest size of the fine contrasts sharply with the prior regulatory findings. Leonteq’s public statements in 2025 claimed that regulatory legacy matters were drawing to a close, despite serious enforcement actions issued in consecutive years. The gap between the firm’s messaging and the regulatory trajectory further compounds the lack of clarity.

The inability to reconcile internal and external audits, SAR timing, supervisory findings, and public statements points to a deeper challenge in understanding the true scope of the problem. Internal reviews may have been constrained or incomplete, audits could have focused narrowly on documentation rather than systemic patterns, and regulators may have withheld details for confidentiality or ongoing investigations. The inconsistencies across jurisdictions raise concerns that the full extent of the issues remains undisclosed. BaFin and FINMA uncovered systemic control failures, and the ACPR referred potential money laundering and fraud to prosecutors. Yet the final BaFin penalty was minimal and accompanied by almost no explanation, prompting questions about whether the regulator is limiting public scrutiny or withholding more serious findings.

The minimal disclosure may also reflect an attempt to close the matter without fully addressing underlying issues. Leonteq’s earlier assertions about complete documentation were contradicted by the ACPR, suggesting that the firm’s communications may not have aligned with regulatory expectations. The possibility that Swiss or German authorities could be masking a larger scandal cannot be dismissed given the contradictions, the small fine, and the multiple cross-border findings. Without clear and complete reporting, stakeholders are left to piece together fragmented information, leaving unresolved concerns that the issues may be more extensive than publicly acknowledged.

By fLEXI tEAM