Bass, Berry & Sims attorney Thad McBride commented on a recently released report on enforcement trends and fines levied for sanctions and other financial crimes. According to the report, which was published by the data analytics company Corlytics, 97% of fines imposed for financial crimes in the last five years have been imposed by U.S. authorities. As Thad notes, “many of the largest penalties, especially for sanctions violations and for AML violations, have been imposed against non-U.S. banks. That certainly suggests that the U.S. government has been and is likely to continue to be comfortable exercising long-arm jurisdiction over non-U.S. entities.”
Thad also noted the report’s finding that “other countries have pursued individuals more aggressively than the United States.” Thad suggested that “perhaps it is that type of individual enforcement by its non-U.S. counterparts that has made the U.S. government explicitly emphasize its intent to pursue individuals going forward.”
The full article, “Enforcement Trends: U.S. Leads The Way With Colossal Fines,” was published by PaymentsCompliance on September 12, 2017, and is available online (subscription required).