Not long ago, U.S. settlements in the hundreds of millions of dollars for violations of American law by a foreign bank seemed unlikely, if not out of the realm of possibility altogether. Then came the $780 million deferred prosecution agreement with UBS AG in 2009.
Although headline-grabbing settlements north of $1 billion have become the new normal for depository institutions operating in the United States, how those deals are impacting bank behavior is still unclear, at least for now, according to Brandon Garrett.