Tag: Panama Papers

Paradise Leaked: An Analysis of Offshore Data Leaks

Posted on January 31, 2022 | Policy Brief

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In recent years, there have been several high-profile leaks of documents related to the offshore financial industry, such as the Pandora Papers released last year. Some of the data contained in the leaked documents have now been made public. In this brief, we discuss the advantages and pitfalls of using these data for economic analysis. We show that despite some caveats, there are patterns in these data that can shed light on a secretive industry. For instance, the number of offshore entities linked to a country increases significantly when that country experiences a change in political leadership. By contrast, financial sanctions on a given country result in a reduction in the number of established offshore entities. In the immediate aftermath of the financial crisis, many countries signed bilateral treaties with tax havens in order to promote transparency. Our analysis of the leaked data shows that the overwhelming majority of offshore entities are not governed by these treaties.

“… that I may see and tell of things invisible to mortal sight.”

John Milton, Paradise Lost

Offshore Tax Haven Leaks

Zucman (2013) estimates that household wealth held in offshore tax havens is equivalent to 10% of world GDP. While there are many legitimate reasons for wealthy individuals to use offshore financial services, the secrecy surrounding offshore holdings has also enabled tax evasion and money laundering. The international community has launched several initiatives trying to increase the transparency of offshore wealth holdings. Over the past decade, several large collections of documents from offshore financial service providers have been leaked to the media: Pandora Papers (2021), Paradise Papers (2017/2018), Bahamas Leaks (2016), Panama Papers (2016), and Offshore Leaks (2013). Investigative journalists have used information from the leaks to expose many instances of secretive financial dealings linked to political leaders. Examples from FREE network countries include: the connections between a close ally of Belarussian President Alexander Lukashenko and a gold mining venture in Zimbabwe, the offshore business holdings of past and present Ukrainian presidents and their respective allies, and the wealth of Russian President Vladimir Putin’s close associates and childhood friends (see, for instance, Cosic 2021, Mylovanov and Mylovanova 2016).

The International Consortium of Investigative Journalists (ICIJ) has made public information on more than 800,000 offshore entities that are part of the offshore data leaks (see ICIJ Offshore Leaks database). The data contain information on the names of companies or people who set up offshore entities, their country of origin, the offshore jurisdiction, and the dates of incorporation and deactivation for offshore entities.

What Can We Learn from the Data?

Despite the wealth of information that this database contains, there has been relatively little academic research using the offshore leaks data. Two notable exceptions are Alstadsæter, Johannesen and Zucman (2019), and Londoño-Vélez and Ávila-Mahecha (2021), who link information from the Panama Papers to administrative records from Scandinavia and Columbia, respectively. They find that tax evasion is concentrated among the richest households. Guriev, Melnikov and Zhuravskaya (2021) use the revelation of the Panama Papers to study its effect on perceptions of corruption.

There are several challenges to using the offshore leaks data for systematic data analyses. First, there are both legitimate and illegal uses of offshore financial services, and without further information, it is not possible to distinguish between them. Second, as this information is obtained through leaks at specific offshore services providers, the data are unlikely to be representative of overall offshore financial activity. Third, there is no information on financial transactions, and we do not know the amounts of money involved in the offshore entities. Finally, more sophisticated offshore structures may make it impossible to deduce the ultimate owner of each entity and its country of origin. Especially for the second and third reasons, economists have tended to focus on balance of payments statistics and cross-border bank deposit data when estimating flows to offshore accounts. For example, Andersen, Johannesen, Lassen and Paltseva (2017) show how the oil wealth of countries with weak institutions is diverted into secret offshore accounts. Becker (2019) investigates recent trends in Russian capital flows and shows that a significant share of Russian money flows to Western European banks. See also Nyreröd and Spagnolo (2018, 2021) for discussions of the role of European banks in recent money laundering scandals.

With these caveats in mind, Figure 1 shows the correlation between the number of offshore entities in the data (on the y-axis) and the offshore wealth holdings of each country’s households (on the x-axis) as estimated by Alstadsæter, Johannesen and Zucman (2018). While the chart shows a positive correlation of 0.56 between these two measures, it also illustrates that the number of leaked entities may be a poor proxy for the stock of offshore wealth. Countries with a significant fraction of offshore wealth in European tax havens are underrepresented in the leaks (e.g., France, Germany, and Italy) while the UK, Russia, and Latvia account for a disproportionate share of leaked offshore entities.

Figure 1. Number of offshore entities and estimated offshore wealth

Source: ICIJ Offshore Leaks database, Alstadsæter, Johannesen and Zucman (2018) and authors’ calculations.

Timing of Offshore Entity Creation

While the number of overall leaked entities per country might not be a perfect measure of the amount of offshore wealth, we find that there are systematic patterns in the timing of the creation of offshore entities. In particular, more offshore entities are created when individuals face political uncertainty in their own countries and fewer offshore entities are created by individuals from countries under financial sanctions.

Elections and Change of Leadership

Figure 2 shows the average number of newly incorporated offshore entities linked to a given country (on the y-axis), depending on that country’s political situation. Panel A shows no clear pattern of offshore entities being created by companies or individuals around the time of elections. Elections are often predictable and frequently result in the reelection of the incumbent government. In contrast, Panel B shows a clear increase in the number of offshore entities linked to a country around the time when that country experiences a change in the de facto political leader. Around four months before there is a change in political leadership, the average number of entities created per country per month almost doubles. Offshore entity creation falls back to normal levels typically around half a year following the transition of power. This pattern suggests that wealth leaves countries at times of political uncertainty and is consistent with the findings of Andersen, Johannesen, Lassen and Paltseva (2017) and Earle, Shpak, Shirikov and Gehlbach (2021).

Figure 2. Offshore entity creation and national political situation

Panel a. Elections

Panel b. Change of political power

Source: ICIJ Offshore Leaks database, The Rulers, Elections, and Irregular Governance (REIGN) Dataset and authors’ calculations. A change of power is defined as a change in the de-facto political leader (e.g., due to the incumbent losing an election or the collapse of a coalition government).

International Sanctions

Figure 3 shows the impact of sanctions from the United Nations, European Union, and the United States on the average number of offshore entities linked to a given country (on the y-axis). Panel A shows that when a country is subject to financial sanctions, the number of linked offshore entities created falls to around 10 per year from an average of 25 before the introduction of sanctions. The impact of sanctions can already be seen in the year before the start of the sanctions, which could reflect measurement and reporting errors or anticipation of the sanctions. In contrast, Panel B shows that trade sanctions that are not accompanied by financial sanctions have no significant impact on offshore activities. These charts suggest that financial sanctions may have some impact on how much capital can be moved from countries under sanctions to offshore accounts.

Figure 3. Offshore entity creation and international sanctions

Panel a. Financial sanctions

Panel b. Trade (without financial) sanctions

Source: ICIJ Offshore Leaks database, Global Sanctions Data Base and authors’ calculations.

Promoting Transparency

After the Financial Crisis in 2009, G20 countries compelled offshore tax havens to sign bilateral treaties to allow for the exchange of banking information under the threat of economic sanctions. More than 300 treaties were signed by tax havens that year. The effectiveness of this policy has been debated. For instance, Johannesen and Zucman (2014) show that the treaties lead to a relocation of bank deposits from compliant to less compliant offshore tax havens.

The G20 crackdown required each tax haven to sign at least 12 bilateral treaties. Relative to a comprehensive multilateral agreement, this policy had two limitations. Firstly, it leaves room for the diversion of funds identified by Johannesen and Zucman (2014). Secondly, tax havens were able to choose freely among potential partner countries – regardless of the underlying financial flows. Figure 4 shows that only a small fraction of the entities in the offshore leak database have a country of origin that signed a treaty with the tax haven in which they were incorporated. In addition, the small share of entities that will be subject to treaties suggests that havens did not always sign treaties with the most important counterparts. While the leaked entities may not be representative of offshore finance as a whole, this picture appears inconsistent with the OECD’s claim that “the era of bank secrecy is over” (OECD 2011)

Figure 4. Entity creation by treaty status

Source: ICIJ Offshore Leaks database, treaty events from Johannesen and Zucman (2014) and authors’ calculations.

Conclusion

A series of leaks over the past decade have exposed over 40 million documents related to the secretive offshore financial industry. Information related to over 800,000 offshore financial entities has been made public by the ICIJ. While a few high-profile cases received significant media coverage and gave rise to further investigations, the vast majority of references to networks of individuals, trusts, and shell corporations are difficult to decipher. This brief argues that, collectively, these leaked documents can be informative. They can be used to analyze the reasons for moving money offshore (such as domestic political uncertainty) as well as the constraints individuals face when doing so (such as international sanctions or bilateral treaties on bank secrecy).

In an effort to further increase transparency, 102 jurisdictions committed to a new standard for the automatic exchange of certain financial account information between tax authorities from 2019. Until such reforms are successful, leaks by whistleblowers are likely to remain a valuable source of information on the offshore financial industry.

References

Disclaimer: Opinions expressed in policy briefs and other publications are those of the authors; they do not necessarily reflect those of the FREE Network and its research institutes.

Capital Flows from Russia — The Bigger Picture

Posted on April 8, 2019 | Policy Brief

A bunch of dollar bills covering table that represents capital flows in Russia

There is an increasing focus on how Russian capital flows are being channelled through Western banks to various destinations, including offshore havens. There are of course legitimate reasons and legal ways of moving capital across borders, but much of the international focus on capital flows in recent decades is linked to the financing of terrorism, tax evasion, and money laundering in connection with criminal activities. This brief provides the macro view of capital flows between Russia and the rest of the world to paint the bigger picture behind the more specific stories we read about in the news that involve individual businessmen, corrupt officials, criminals, and banks.

International capital movements have a clear role in allocating resources efficiently across countries. However, today’s media coverage instead typically focuses on the role of capital flows in financing terrorists and avoiding taxes. Recently, money laundering has been creating headlines around the world in the Panama papers and other similar stories, illuminating complicated schemes in the global financial system in connection with illegal activities such as tax evasion, corruption, drug dealing and human trafficking.

In the international policy making arena, since 1989, the Financial Action Task Force (FATF) has the objective “to set standards and promote effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and other related threats to the integrity of the international financial system”. After the terrorist attacks in 2001, the issues of anti-money laundering (AML) and combatting the financing of terrorism (CFT) also became a central area of the IMF’s work and has since become an increasingly important policy question.

In several of the news stories, money flowing from Russia features prominently. This brief provides the bigger picture of Russian capital flows based on publicly available data as a complement and background to the news stories that are based on inside information, or “leaks”, and that focus on particular individuals and banks.

Composition of capital flows

In the official balance of payments statistics, capital flows are divided into a number of different categories, for example, private vs public or banks vs non-banks. There is also a distinction made between foreign direct investments (FDI) on the one hand and portfolio flows, loans and other types of transactions (PLO) on the other. Since the balance of payments also has to balance (despite the fact that not all international transactions have been recorded) there is also a term called errors and omissions (E&O) that take care of various discrepancies. In environments with poor data collection and a large share of activities that take place “off the books”, this term tends to be large. For Russia, this term has become smaller over time as the economy and data collection has matured.

In terms of volatility and magnitude of flows, the distinction between FDI and PLO is often important and so also in Russia. Figure 1 shows the private sector flows to and from Russia over the last two plus decades.

Figure 1. Capital flows to and from Russia

Source: Central Bank of Russia and author’s calculations

After a rather slow start in the early years of transition, capital flows took off as Russia started to generate growth in 2001, and the flows kept growing until the global financial crisis. As expected, FDI flows have been less volatile than PLO flows but perhaps more surprising, in- and outflows in both categories seem to move closely together (see Becker (2019) on why this is the case). We can also note that there has been a marked downturn in flows at the time of the annexation of Crimea and subsequent sanctions and counter sanctions between the West and Russia.

Cumulative capital flows

By computing net flows from the data in Figure 1 and accumulating this over time, we get a clearer idea in Figure 2 of the massive amounts of capital that have left Russia over the last decades. In the early years, the outflows were in the form of errors and omissions (E&O) and PLO, but the PLO trend was reversed in the early 2000’s and turned total accumulated flows back to zero before the global financial crisis hit. The global financial crisis was a clear turning point for capital flows in general and PLO flows in particular.

Figure 2. Net private capital flows

Source: Central Bank of Russia and author’s calculations

In the year following the global financial crisis, almost USD 300 billion left Russia. Outflows then continued, albeit at a slower pace, only to accelerate again at the time of Russia’s annexation of Crimea. By mid-2018, USD 700 billion had left Russia since 2008, mainly in the form of PLO flows. This is equivalent to twice the amount of fixed capital investments in Russia in 2017.

For a country like Russia that is in need of increased investments both from domestic and foreign sources to generate long-term sustainable growth, these outflows are very costly at the macro level even if they are beneficial to individual entities that are behind the flows.

Destinations of capital flows

Where the money from Russia ultimately ends up should matter less to people in Russia than the fact that they are not invested and generating growth at home. However, it can matter a great deal to people, policy makers and businesses in the destination countries. Not only because it involves business opportunities and employment to some, but also because it generates concerns among regulators, law enforcement and tax authorities regarding the origins and purposes of the investments.

We do not have full coverage of where all the money Russian entities invest or park abroad end up, but official statistics are available for at least part of the investments. First of all, there is data on cross-border assets and liabilities of the banks that report to the Bank of International Settlement (BIS), which shows what foreign residents have deposited in the banks. Russian claims on BIS reporting banks are shown in Figure 3, where we can note that total claims by Russians amount to USD 131 billion. Half of this amount was deposited with French, Swiss, UK, and Belgian banks at the end of September 2018.

Figure 3. Russian claims on BIS reporting banks in different countries (USD bn, Sept. 2018)

Source: BIS and author’s calculations

Given the recent scandal in Danske Bank, we can also note that USD 8 billion was deposited by Russian entities in Danish banks, which may not sound much in this context but amounts to around 2 per cent of Danish GDP.

Again, macro level data does not tell us if the flows behind the numbers are illicit or legitimate, but it provides some sense of the order of magnitude and possible significance for the entities involved in the transactions and their regulators and supervisors.

The next piece of information is due to the IMF’s and others’ efforts to collect and harmonize data on the destination of portfolio and FDI assets, and the data for Russia is presented in Figures 4 and 5.

The prime locations for Russian owned portfolio assets are Ireland and Luxembourg, followed far behind by the Netherlands, UK and US. In total, official portfolio assets are rather modest at USD 69 billion, which is far off the cumulative net PLO flows in Figure 2 of over USD 500 billion even if we add the BIS reporting bank deposits in Figure 3.

Figure 4. Russian portfolio assets by the destination country (USD bn, Sept. 2018)

Source: Central Bank of Russia and author’s calculations

This could have many explanations, including that a significant share of Russian PLO assets is not in BIS reporting banks or in countries that provide transparent reporting of other types of PLO assets. The fact that cumulative flows and stocks reported in international statistics are so different, though, clearly asks the question where the remaining assets are invested.

The last component for which we have data is the location of Russian FDI assets. This turns out to be the most significant asset class available in the official statistics with a total of USD 364 billion invested abroad. Given that the magnitudes of FDI flows in Figures 1 and 2 are much smaller than PLO flows, this is somewhat surprising. Less surprising is the fact that more than half of this is invested in Cyprus, which is a well-known destination for Russian money.

However, it also begs the question on how assets are classified and where; Cyprus annual GDP was USD 24 billion in 2018, or 13 per cent of what is classified as Russian FDI assets in Cyprus. The only reasonable interpretation is that Cyprus is an offshore destination to park Russian money and not the ultimate location of direct investments from Russia. It is not unlikely that similar explanations are also valid for a significant share of the assets recorded as investments in the Netherlands, Austria and Switzerland, not to mention the British Virgin Islands (BVI) or the Bahamas. This problem is not unique for Russian data, but the magnitude of the problem regarding this data is still striking.

Figure 5. Russian FDI assets by the destination country (USD bn, Sept. 2018)

Source: Central Bank of Russia and author’s calculations

Policy conclusions

Capital leaving Russia is mainly a problem for investments and growth in Russia, but, as has become far too clear recently, some of the flows also create problems in other countries. In particular, flows that are associated with money laundering and channelled through financial institutions in the West can create massive problems for banks that do not have sufficient control mechanisms in place or are guided by short-term profit maximization that encourages staff to look the other way when illicit flows are coming in.

Given the massive scale of flows coming from Russia, it can obviously be tempting to be part of this business while at the same time very costly to implement procedures and routines that control all of the flows adequately. However, not understanding the bigger picture of Russian flows can be even costlier.

References

Disclaimer: Opinions expressed in policy briefs and other publications are those of the authors; they do not necessarily reflect those of the FREE Network and its research institutes.

Money Laundering: Regulatory or Political Capture?

Posted on December 10, 2018 | Policy Brief

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Danske Bank has recently been accused of having laundered more than 200 billion Euros through its Estonian branch. The size of the scandal has reinvigorated the discussion over lax enforcement by regulators and poor bank compliance with anti-money laundering laws. In this brief, we concisely review some recent cases of poor regulatory and political behaviour with respect to these matters, focusing in particular on the UK, whose financial system seems to have become a main hub for this type of financial misconduct.

A widespread phenomenon

The size of the recent money laundering scandal at Danske Bank, involving more than 200 billion Euros, has surprised many. Money laundering is a widespread issue in an increasingly complex world where financial transactions are many and instantaneous, while oversight slow and limited (Radu 2016). According to the United Nations Office on Drugs and Crime, an estimated $800 – $2 trillion is laundered every year (United Nations Office on Drugs and Crime). The source of laundered money is often from corruption, crime and drug cartels (as with the HSBC scandal, see below). Attempts to blow the whistle on these illegal transactions have gotten several people killed, especially in Russia (The Daily Beast, October 2018).

Malta’s Pilatus bank recently had its license revoked by the European Central Bank after its chairman was charged with money laundering (Reuters, October 2018). The investigative reporter Daphne Caruana Galizia was killed in a car bomb in October of 2017 in Malta (The Guardian, October 2017). She was leading the Panama Papers investigation into corruption in the country and had accused Pilatus bank of processing corrupt payments (The Guardian, November 2018). In Sweden, some banks have recently been criticized for insufficient actions against money laundering. Experts at the regulator recommended extensive sanctions, but upper management stopped them (Svenska Dagbladet, December 2018). In November, Deutsche Bank’s headquarters in Frankfurt were raided by prosecutors in a money laundering investigation (BBC, November 2018).

Back to Danske Bank. Its Estonian branch was recently accused of having laundered money, amounting to over 200 billion Euros of suspicious transfers (Financial Times, November 2018). In 2011 the Estonian branch accounted for 0.5% of Danske Bank’s assets, while generating 12% of its total profits before taxes. In 2013, 99% of the profits in the branch came from non-residents. Many of the non-resident customers are believed to be from Russia and other ex-soviet states (Forbes, September 2018). The alleged money laundering came to light due to the whistleblower Howard Wilkinson, who headed Danske Bank’s market trading unit in the Baltics from 2007 to 2014. Surprisingly, his anger over these transactions was not primarily aimed at top management in Copenhagen, or failure of rank and file employees to follow protocol in customer acquisition, but against the UK, who he claimed is “the worst of all” when it comes to combating money laundering (Financial Times, November 2018). In fact, the UK institutions seem to have been at the very heart of the scandal (ibid):

“Mr Wilkinson’s emails to Danske executives in 2013 and 2014 highlighted how UK entities were “the preferred vehicle for non-resident clients” at the heart of the scandal.”

In an address to European Union Lawmakers, he said (Reuters, November 2018):

“The role of the United Kingdom is an absolute disgrace. Limited liability partnerships and Scottish liability partnerships have been abused for absolutely years”.

Regulatory or political capture?

The increasingly central role that the UK appears to be playing as a hub for financial crime is perhaps not new or surprising. The UK has indeed come to be widely recognized as one – though certainly not the only – main hub for these illegal transactions (see e.g. Radu 2016, p.15). The UK’s National Crime Agency estimates 93 billion GBP of tainted money is flowing into Britain annually (Financial Times, September 2018).

And according to the classic theory of regulatory capture (Stigler, 1970), it is to be expected that a large, wealthy and highly concentrated sector such as the UK financial industry, will be able to capture regulatory institutions and lead them to act more in its favour than in that of the (national or international) community. However, besides being a concentrated source of special interests, the financial sector also represents a large share of the UK economy. It could be the case, therefore, that the capture goes all the way up to the political system and the government (as in Becker 1983, and Laffont, 1996). So, is it the alleged crime-friendly environment in the UK financial system linked more to problems of regulatory capture, or to deeper political capture?

Already in 2004 there were worrying signs of possibly deep political capture.  At the time, Paul Moore, a senior risk manager at Halifax Bank of Scotland (HBOS), raised concerns about the bank’s risk taking and was subsequently fired by the executive James Crosby. Crosby then proceeded to become Deputy Chairman at the Financial Services Authority (FSA). HBOS then collapsed during the financial crisis of 2008 and merged with Lloyds bank, leading to one of the most concentrated banking systems in the world (the top 5 banks have 85% of the UK banking market). Many took this to substantiate Moore’s claim that the bank had been taking excessive risks. During Prime Minister’s question time in the House of Commons, David Cameron commented on then Prime Minister Gordon Brown’s decision to appoint Crosby to the FSA:

“Sir James Crosby, the man who ran HBOS and whom the Prime Minister singled out to regulate our banks and to advise our Government, has resigned over allegations that he sacked the whistleblower who knew that his bank was taking unacceptable risks.” (cited in Dewing and Russell 2016, p.165)

A suggestive episode directly involving politicians and money laundering is the case of HSBC, with headquarters in London. HSBC avoided criminal prosecution in the US and entered into a deferred prosecution agreement with the DOJ in 2012 (Department of Justice, December 2012). HSBC was found to have violated U.S. Anti-Money Laundering and Sanctions Laws by laundering billions of dollars linked to Mexican drug cartels, groups in Iran and Syria, and groups linked to terrorism. While HSBC apparently had systems to flag suspicious transactions, employees were told to disregard red flags (Garrett 2014, p.201). The case led to a 2016 House Committee report entitled “too big to jail” that was extensively used against the Democrats by the Trump presidential campaign (Committee on Financial Services, 2016).

The report states that on the 10th of September 2012 UK Chancellor George Osborne (the UK’s chief financial minister) wrote a letter to Federal Reserve Chairman Ben Bernanke (with a copy transmitted to then Treasury Secretary Timothy Geithner). In the letter, Chancellor Osborne insinuated that the U.S. was unfairly targeting UK banks by seeking settlements that were higher than comparable settlements with U.S. banks. He also worried about what criminal sanctions against HSBC would imply for financial stability. Criminal charges could also lead to a revoked license, making the bank unable to do business in the US (Financial Times, July 2016). HSBC was eventually ordered to pay a 1.9 billion dollar fine, while another whistleblower claims that the money laundering still went on (Huffington Post, August 2013).

The FSA also appeared much more concerned about criminal sanctions against HSBC than with money laundering for the bloodiest drug cartel in history (estimated to be responsible for several tenths of thousands of murders). In fact, the house committee report states that “The FSA’s Involvement in the U.S. Government’s HSBC Investigations and Enforcement Actions Appears to Have Hampered the U.S. Government’s Investigations and Influenced DOJ’s Decision Not to Prosecute HSBC” (p.24).

Things have not improved more recently. In 2013 the FSA was split up into the Financial Conduct Authority and the Prudential Regulation Authority (FCA & PRA). In 2014 the FCA & PRA came out with a note requested by the British parliament on whether financial incentives for whistleblowers should be introduced in the UK. These financial incentives, or reward programs, are used extensively in the US in tax, procurement, and securities. The FCA & PRA came out strongly against rewards in their seven-page note, yet do not cite a single piece of evidence (PRA and FCA, 2014). Most importantly, the note contains important factual misstatements about available evidence on their effectiveness that were easy to check at the time of the report (Nyreröd & Spagnolo 2017, National Whistleblower Center 2018). Nor was the note amended when one of us repeatedly communicated the mistakes to the agencies. This suggests persistent and deep regulatory capture. Consistent with this interpretation is the sanctioning behavior of UK regulators.

A blatant recent example is the ridiculous fine against CEO of Barclays Bank Jes Staley. He ordered his security team to unveil the identity of an uncomfortable whistleblower, going so far as to request video footage of the person who bought the postage for the letter. Yet, the FCA & PRA decided to just fine him £642 000 – a small fraction of his pay package that year (Reuters, May 2018). When Moore was asked about the fine he replied that “it is a very clear sign to whistleblowers not to bother” (Reuters, April 2018).

Conclusion

Is this regulatory capture, or political capture? The impressive list of consistent cases of regulatory slack and of political complacency suggests both, at least in the case of the UK. But the problem of regulatory capture in the case of financial crimes goes way beyond the somewhat extreme case of the UK. In all jurisdictions financial misbehavior has recently only led to settlements between regulators and the infringing financial institution, with settlement payments way too low to generate (financial stability concerns, and) deterrence effects. Banking regulators appear mainly concerned about banks’ health and profitability, so that large financial institutions have not only become too big to fail, but also too big to jail, and now even too big to fine, at least to the appropriate extent (Spagnolo 2015). All this even though the financial crime has been that actively supporting through money laundering criminal organizations that killed tenths of thousands of innocent people.

References

Disclaimer: Opinions expressed in policy briefs and other publications are those of the authors; they do not necessarily reflect those of the FREE Network and its research institutes.