(Editor's note: The evidence is damning but, as ever, the question to ask is what can be done about it? Fines are clearly a deterrent if they are large enough, but there remain a number of challenges. To begin with, there is a strong sense that different rules seem to apply to US-based banks than for the rest of the world. However, unfair a perception that may be, the US authorities' aggressive use of extra-territorial power to chase crooks when dollars are used is not often matched on the European side. Technology can play a big role in screening for dubious funds and enforcing rules, but it is not always sufficient, or a substitute in some cases for judgement. Some of the issues come from how money from the former Soviet Union and the Middle East finds a natural first home in Europe, so this is a region more likely than some others to feel the heat. It is not always clear whether the European Union has the means or the will to act sufficiently yet, although countries acting alone can achieve only limited progress. Sadly, when the stakes are high enough, dirty money will find a way of getting through. But clearly, this industry needs to raise its game.)