But is it really 'us against them' when it comes to sanctions or do financial institutions and regulators have a shared objective in this increasingly important area?
Of course, such massive fines are indicative of zero tolerance among regulators for breaches of sanctions. Rightly, there is a line in the sand which says deceptive practices will not be tolerated.
We all have an interest in global financial security and international sanctions support and, as evidenced by recent events regarding Mossack Fonseca, discussions about how we achieve this are more important than ever.
Regulators are increasingly recognising a shared approach to reaching this goal is the best way forward.
ANZ recently hosted Jamie Rose from the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury as part of their outreach activity intended to help institutions understand their sanctions obligations.
This type of partnership approach is important. There's a shared need for regulators and banks to share information, so financial institutions are clear on what is expected of us and can ensure we work to optimise the flow of transactions and maximise levels of compliance.
At ANZ, to achieve this across the 34 countries in which we operate, we aim to implement a high waterline – a standard above the minimum level in all the countries in which we operate.
While this may mean meeting rules we don't need to – for example meeting sanctions requirements in relation to Cuba, which only apply to the US – this approach makes it simple for our people to understand and meet our obligations.
The alternative would mean attempting to implement the sanctions requirements of every country and then monitoring transaction by transaction, customer by customer, to ensure we comply with any laws which might apply to that transaction and the nationalities of the people involved.