I think what we’ve learned by now is that every international bank in the world may have violated US anti-money laundering guidelines, specifically when it came to doing business with countries barred by sanctions. Royal Bank of Scotland is only the latest, and you can add it to the growing list of firms we know engaged in this, including Standard Chartered, Wells Fargo, Citi, Deutsche Bank, HSBC, Germany’s Commerzbank, Japan’s Sumitomo Mitsui Financial Group, Holland’s ING Direct and more.

Federal authorities in the US are investigating Royal Bank of Scotland for possible breaches of Iran sanctions in a probe that has already led to the departure of a senior risk manager.

The UK bank is being probed by the Federal Reserve and Department of Justice after volunteering information to them and UK regulators about 18 months ago, several people close to the situation said.

The bank uncovered the alleged failings after chief executive Stephen Hester initiated an internal review not long after his arrival three years ago.

We don’t have to limit this to banks, actually. Hewlett-Packard, Cisco and Sun Microsystems all did business with Iran in violation of formal sanctions, over a multi-year period.

Whether you agree with the Iranian sanctions regime is one matter. But you cannot deny that a substantial amount, if not most, multinational corporations viewed the sanctions as immaterial to their profit-making schemes.

And most of this remained relegated to the back pages of the business section until Benjamin Lawsky, the head of New York’s Department of Financial Services, took a stand with Standard Chartered Bank, and demanded that they defend their license to practice business in the state in a formal hearing. This led to a much larger settlement fine, in relative terms, than federal regulators had been granting for money laundering violations. And more important, it led to the reluctant move by regulators to acknowledge these other violators and ongoing investigations. I firmly believe that we wouldn’t be hearing about these cases without Lawsky’s move. The federal regulators are trying to save face now.

Simply put, the Treasury Department’s Office of Foreign Assets Control, which supposedly monitors the sanctions regime against Iran, does virtually nothing to stop violations before the fact, and would have done precious little after the fact, were it not for one pesky state regulator.

David Dayen

David Dayen