@Sampo1 @Keketin I suppose these days they want to apply the group’s turnover rather than the turnover of an individual outfit. Otherwise, banks could totally isolate their fine risk by bundling shady operations into their own subsidiary. As I understand it, however, that turnover is only used for additional surcharges on the fine. The fine amount under the new Anti-Money Laundering Act is primarily proportional to the volume of questionable transactions. The old one was more obscure. In addition, it is interpreted whether economic benefit was gained by neglecting processes, etc.
Also, since there is likely a dispute over legal interpretation involved, it’s quite certain that the whole thing will drag on for years. Even if the first decision comes this year, the losing party will most likely appeal.