The document discusses trends in civil penalties for anti-money laundering (AML) non-compliance and violations. It notes that while the number of fines has decreased, the penalty amounts have sharply risen. Some of the largest financial institutions have been assessed huge penalties for non-compliance. With more strict economic sanctions and enforcement, financial institutions need robust compliance programs to minimize risks of penalties that can include large financial penalties, sanctions, imprisonment, and reputational damage. The document recommends measures like good governance, strong internal controls and audits, and investment in new technology and processes to avoid penalties for non-compliance.