NOTE TO DEPARTMENT OF JUSTICE: ITS NOT ABOUT THE MONEY, ITS ABOUT THE DIRECTORS

This week's news includes details of the departure of a senior member of the Department of Justice; this individual distinguished himself by obtaining extremely large civil fines and penalties from major banks and corporations. Such actions, while they may temporarily hurt the bottom line of the biggest banks and corporations, only result in smaller annual dividends for the shareholders, and some temporary adverse publicity and reputation damage, in my humble opinion.

Unless the Department of Justice will finally get around to indicting those bank and corporate directors who pay lip service to compliance, while engaging in willful blindness, for the sake of lucrative profits, we will never deter future violations. The directors are the ones who overrule compliance officers, in favor of dodgy, or downright illegal, clients that are cash centers, and they need to go to Federal Prison, in sufficient numbers as will deter the others from breaking the law. The law says: directors must direct, and that includes AML/CFT. Hold their feet to the fire, please, when they fail to discharge their obligations to the law.