Page 55 - Monocle Quarterly Journal Vol 1 Issue 1 Q4

Rather than examining this question of geopolitical preference sub- jectively, we made the decision to limit the study and the construction of the nes database to countries that have a long history of responsible nancial and risk reporting standards in order to create a database of greater accuracy. We settled upon the G8 as the logical starting point of the study.
Secondly, we decided to limit the study to individual bank ne events that constituted nes of greater than USD 1 million in value. roughout the G8 countries, banking institutions, as well as corporations from several other industries, are regularly ned for indiscretions at an individual customer level, for values far below USD 1 million. is would be true for example within the telecommunications industry, for small indiscretions such as incorrect billing or for not maintaining and updating personal information. ese issues are usually resolved by an industry ombudsman and are commonplace. We believed that the key insights that we wished to observe would not be contained within this level of detail, and that the database would be su ciently indicative rather than complete if we were simply to create a lower bound threshold.
irdly and nally – as an introductory point – we made the decision to only include nes that we could validate from pure source material. e Financial Times, as an example, has on several occasions published results based on their own research and database. It was extremely useful to make reference to this dataset, but we insisted internally that all nes data should be backed up by source material from either the ned entity or from the regulator or legislator itself.
As an example, we made a thorough study of the Department of Jus- tice document detailing the misconduct of Bank of America in their malfeasance in misleading customers through its Countrywide subsidiary in terms of selling mortgages irresponsibly. We needed to fully digest the legal documentation in its entirety so that we could accurately capture precisely which laws had been broken, as well as precisely where the money from the nes would be allocated. Often this involved reading and summarising detailed legal documentation and breaking the headline- capturing staggering ne value into smaller amounts and accruing these amounts to the various Federal and State entities that participated in the actions against the bank.
Ultimately, the database elicited in excess of USD 138 billion in nes levied by G8 countries against G8-domiciled banks between the
“Ultimately, the database elicited in excess of USD 138 billion in nes levied by G8 countries against G8-domiciled banks between the beginning of 2007 and the end of 2015.”
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