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$7m is a slap on the wrist for the sort of thing we're talking about, and coming clean shouldn't be a get out of jail free card either, which brings with it all

• kazinator 10y ago
  Would you like someone to actually slap you on the wrist every time you make an innocent mistake in which there are no actual damages and nobody is hurt? This is not a case where the company failed to transfer money owed to the government. And even in such a case, the appropriate remedy would be actual damages plus interest, where the interest is at some punitive rate. Because some transactions were innocently concealed, the damage is that the government may have lost some opportunities to catch some people laundering money through those branches of the bank. But that is very indirect. In any case, in those cases they would probably have existing suspicions, right? And they would notice that, oops, that person is using a branch for which we have no data from Citigroup: how come? The SEC didn't catch this error precisely because they were not investigating any user of those branches for which data were missing. They only lost the opportunity represented by situations in which the data is the primary source of the initial suspicion of wrong-doing. That is all. As in, something in the numbers raises a red flag, and then they investigate and uncover something. Well, they have the data now; they could comb through it, right? This 15 year period, or at least most of it, should be well within the statutes of limitations that they could still prosecute cases uncovered by the data.