Financial institutions faced with government enforcement actions confront not only the direct costs of fines and penalties, but a host of collateral consequences, as well.

As the regulatory landscape grows more cluttered, some firms have been forced to resolve numerous investigations, creating the appearance (rightly or wrongly) of serial bad behavior. And regulators—in particular, the U.S. Securities and Exchange Commission—are keeping track of serial settlements and seeking new ways to remedy the “failed compliance culture” that some officials believe presently exists in parts of the industry.1

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