The United States occupies a uniquely important place in this global effort to rid the world of dirty money. As the regulator of world’s largest economy and the issuer of the global reserve currency, the U.S. government exercises disproportionate regulatory and law enforcement power over the global economy and has unparalleled visibility into its workings. U.S. laws against bribery, fraud, and money laundering have an exceptionally long extraterritorial reach. Just as significantly, the role of U.S. correspondent banks in facilitating dollar-denominated transactions means that their regulator, the Treasury Department, can at the stroke of pen exclude foreign actors from the U.S. financial system. Such designations can make an economic pariah out of individuals and firms that would otherwise be beyond the reach of U.S. law. 

At first blush, the United States seems to be pulling no punches. In 2019 alone, U.S. fines issued in connection with non-compliance with money laundering, customer due diligence, and sanctions regulations exceeded $8 billion. Fines under the Foreign Corrupt Practices Act, which criminalizes bribes to non-U.S. officials, totaled $2.6 billion, the highest figure since the law was passed in 1979. These numbers dwarf those of any other country, even accounting for the size of the U.S. economy. Since 2017, furthermore, the United States has for the first time been imposing economic sanctions on individuals who engage in corrupt activities…

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