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RBS: The Dumbest Bank Of 2013?
The realization that RBS is not exactly populated by the sharpest tools in the shed first hit roughly two years ago, when its crack fixed income team was fined $1.9 million for not knowing the difference between Price and Discount, as was shown in the Dynegy CDS settlement auction. However, that episode was rocket surgery compared to what Bloomberg's Jonathan Weil uncovered, which rightfully prompted him to award RBS the "dumbest bank of the year" award for 2013.
From Bloomberg:
Back in 1999, after the notorious con man Martin Frankel went missing, federal agents found a partially burned to-do list at his mansion in Greenwich, Connecticut. Item No. 1 on the list: "Launder money."
Royal Bank of Scotland Group Plc might not have topped that one, but it came close enough to win this year's "Dumbest Bank of the Year" award. OK, that's not a real award, but it should be.
RBS, which is still government-controlled more than five years after taking a U.K. taxpayer bailout, will pay $100 million to federal and state banking regulators as punishment for using U.S. correspondent banks to conduct transactions with customers in Iran, Sudan and other countries subject to international sanctions. Often, violations of the law are difficult for banking regulators to establish, because the evidence tends to be gray and open to interpretation. That doesn't seem to have been a problem in this instance.
According to a consent order released today by the New York State Department of Financial Services, RBS provided employees at its payment-processing centers in the U.K. with written instructions, containing "a step by step guide on how to create and route U.S. dollar payment messages involving sanctioned entities through the United States to avoid detection."
Those instructions included this:
"IMPORTANT: FOR ALL US DOLLAR PAYMENTS TO A COUNTRY SUBJECT TO US SANCTIONS, A PAYMENT MESSAGE CANNOT CONTAIN ANY OF THE FOLLOWING: 1. The sanctioned country name. 2. Any name designated on the Office of Foreign Asset Control (OFAC) restricted list, which can encompass a bank name, remitter or beneficiary."
In other words, RBS explicitly told employees how to cover the bank's tracks. The consent order said the bank conducted $523 million of transactions from 2002 to 2011 through New York correspondent banks involving Sudanese and Iranian customers. It also said that RBS, to a lesser extent, processed U.S. dollar transactions for clients in Cuba, Burma and Libya.
After a dumb note like that, it's no wonder RBS did the smart thing and settled.
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Wow, just wow!
RBS: Ridiculously Blatant Scumbags!
What would happen to me if I laundered money for Iran?
A spot fine?
people need to stop using deprecated negative-connotation words like "laundering" when in fact they mean "clearing and settlement" instead
http://www.group30.org/rpt_12.shtml
hugs,
paul, jean-claude, stan fisher, and others
http://en.wikipedia.org/wiki/Group_of_30
How much bonus will the bankers get? or else they might leave no?
And yet nobody on here is asking whether a bank outside of the US should actually be subject to the US trying to strong-arm it...
I'm with Muhammad Ali on this one..."I ain't got nothing against them VietCong (or Iranians or Cubans)." In fact I've got friends that started out life in each of those countries. Why should they be punished for the dumb asses that are in charge? (And the same question applies to my situation in 'murica.)
I know, I know...love it or leave it. I love what it once was. I love what Jefferson tried to make it into. I'm not loving the Clinton-Bush-Obama versions...
"I ain't got nothing against them VietCong (or Iranians or Cubans)."
Wanna Bet that RBS was charging double digit processing charges for these transactions? I am sure RBS wasn't doing this to support freedom but out of pure greed.
Makes Dimon's statement about being rich because he's smart look kinda stoopid...anyone is smarter than the RBS fuckers...
"anyone is smarter than the RBS fuckers"
Hmm....not sure about that. The RBS bailout was said to cost UK taxpayers the equivalent of US$69 billion. Goldman Sachs has taken well over $800 billion so far from TAF, PDCF and CPFF alone. JPM is closing in on that $69 billion just in litigation costs and fines to settle London Whales and Madoffs and MERS suits. And there's lots more to come.
I think anyone is smarter than us Merikans that tolerate this crime syndicate of a government.
Naw ... it was for the children.
And that's why Jamie Dimon earns more money than you do, RBS.
London Whale? Tempest in a tea pot. Whodunnit? No idea. Just some rogue traders in the CIO division in London. DID ANYONE EVER TELL JAMIE? No, no, no... and even if they did, you can't prove it.
They should update the list. This guy is dead (allegedly). Supposedly killed in Baghdad in 2002.NIDAL, Abu (a.k.a. AL BANNA, Sabri Khalil Abd
Al Qadir); DOB May 1937; alt. DOB May 1940;
POB Jaffa, Israel; Founder and Secretary
General of ABU NIDAL ORGANIZATION
(individual) [SDT].
OFFICE OF FOREIGN ASSETS CONTROL
Specially Designated Nationals and Blocked Persons List
December 12, 2013
http://www.treasury.gov/ofac/downloads/t11sdn.pdf
This guy is still alive though. ;-/
AL ASSAD, Bashar Hafez (a.k.a. AL-ASAD,
Bashar; a.k.a. AL-ASSAD, Bashar; a.k.a.
ASSAD, Bashar); DOB 11 Sep 1965; POB
Damascus, Syria; President of the Syrian Arab
Republic (individual) [SYRIA].
Isn't this guy dead as well?
BIN LADEN, Usama (a.k.a. BIN LADEN, Osama;
a.k.a. BIN LADIN, Osama; a.k.a. BIN LADIN,
Osama bin Muhammad bin Awad; a.k.a. BIN
LADIN, Usama; a.k.a. BIN LADIN, Usama bin
Muhammad bin Awad); DOB 30 Jul 1957; alt.
DOB 1958; POB Jeddah, Saudi Arabia; alt.
POB Yemen (individual) [SDGT] [SDT].
He is still on the list which was updated Dec. 12, 2013
WTF!?
Yeah, well, it's not like they broke any actual laws. You know, because as the politicians said - "technically didn't break any laws".
Oh hang on, they DID?
Since you are not a banker is it a three spot fine. You get two to the chest and one to the head.
Mozambique drill?
"What would happen to me if I laundered money for Iran?"
or for that matter lie to congress, or lie and steal from the country, or run guns, abandon the Americans in Benghazi, target political groups via the IRS, subvert the constitution daily, destroy the economy through the private FED bank, use the NSA to blackmail and provide insider trading to government officials, rig markets, plot regime change in other countries to destabilize, wars for pipelines, and opium, drones, NSA spying on everything, out of control military industrial complex, etc... fucking etc...
...and how have all these crimes been punished?
Will all the bitchez in the U.S. finally join us in voting Libertarian?
duh! care to bet they're not alone?
they're just the dumbest for getting caught and not having invested in the right regulators
Retarded* Bankers of Scotland.
*FYI*... the original term "retarded" comes from clinical psychology, where it refers to "slow" or literally "late" mental development (from the French "retard", i.e. Late or Delay), and was not a derogatory term it has now become.
So... in purely Clinical terms, I used the term correctly, even if it is now 'politically incorrect'**. You learn something every day, eh?
** Even in my own (extended) family, there are a few members who are so attuned to political correctness, that although they grasp these concepts intellectually, they refuse to use or even hear such words, w/o getting upset at the emotional level.
Clearly the emotional association/bond is so strong for certain "trigger words" for them, that the information never gets to their higher brain functions (logic & reason), or back from it. I find this to be the case for many people, who respond to certain "trigger words" in VERY predictable manner -- either positive or negative manner. Good politicians, PR and sales people know how to use this knowledge to amazing effect and success.
Do you know what YOUR "Trigger Words" are, that get you to respond reflexively (for or against something)? I.e., words that allow others to manipulate you. Think about it.
-K out.
But if you work for them as I did up until they started getting big-headed with the ABN deal, they are:
Royal Bootcamp of Slavery
This is fun. A little Bernanke Humor: https://www.texmetals.com/news/humor-bernanke-yellen-and-the-stock-market/
Headquartered in Scotland. Run by megalomaniac Scot up to 2008. Bailed out by the English taxpayer who is still paying up for hese bozos.
Just give them the civil fine they've already folded into their operating budget.
As always , neither confirming or denying guilt.
Most of that fine is comming out of UK tax collected from the like of me!
Dumb?
Corrupt?
Scheming?
Who the hell knows anymore? This crap gets more surreal and harder to fathom every day. Why the heck hasn't the SHTF by now?
I'm leaning more and more heavily toward converting Fiat into Land. Dirt is real.
Wish I had a Farmer in the family....
You will soon. Whether that farmer is sufficiently proficient to feed his family is up to you.
Hey RE Geek (or anyone):
A little perspective if you please.
I'm looking at 165 acres of mixed use land, about 25% already tilled, and the rest woods/hunting land. Nice log cabin, with new small steel barn/workshop with well and electricity.
Is the current pricing for such properties at an historically low point like the rest of real estate? Subtracting a reasonable cost for the buiildings this land is going for about 1.1 K per acre.
Again, not asking for persepctive on the specific pricing, just the general trend/historical context for valuation of semi-raw land.
Thanks.
i could opine, but i don't want to BS you. My area of expertise is commercial properties. Primarily LA office & retail, so my opinion about land is coming from ignorance. I will say though that I would not contend that pricing in my sector is historically low. It's closer to the other end of the spectrum due to yield chasing. Sorry I can't be of assistance. For what it's worth, I wish I had a setup like you've described.
Hey I appreciate your reply and honesty.
I'm trying to avoid buying at the top.
Thanks for your time.
LOL. Somebody downvoted my simple question. Guess I asked it wrong....
I would say that is a good price if you have water and electricity already....having trees is good too...if the land is fertile another plus..natural rainfall or do you need irrigation...what are the structures worth....is it a tough shed..10x10..or a 40x100 barn....big difference....lof cbins require upkeep...chinking and such...water is their enemy...they rot....you must have access as you have electricity....but with any real estate..it has to do with location..location..location...mountain land in Colorado and Montana is expensive...especially with water..Oklahoma not so much...
Plenty of water-this is in the fertile midwest. Not PRIME farmland but it has been tilled and used for crops.
From the photos, actually I think this is one of those low maintenance log constructions, not raw wood. Auxillary building is new, steel, one level, looks to be about 20 x 30. Might even have a concrete floor.
Thanks for the reply
I'm here in the Midest, flyover country. A lot of people I know are looking for land, but there aren't many people looking in general. The price would be good in my neck of the woods. I know of at least five people that would jump on this if it were sufficiently away from "civilization."
Prices are at a low in these areas...but I predict they will get lower. If you have cash, you'll be in good shape. If you need a loan when those prices are lower, you'll be completely screwed.
I would go 100% cash, and yes, I'm inclined to take a chance and see if this property gets reduced. The current owner just recently "selectively harvested" the prime timber, so I'm working them over on that significant issue.
Sorry for the stupidity, but why would it be hard to get a loan, given the Fed dumping so much liquidity into the market? My bank calls me at least once a month trying to loan me money to "finance my business purchases".
Thanks.
Do some due diligence. There are places where they have been burning properties of outsiders for over a hundred years. High crop yields are incompatible with low productive soil. So if you don't know much about farming you are headed for some hard lessons even if you are betting on a retrograde civilization. This description is what pumpers/flippers do, buy low, sell off timber etc, sell high. Houses have to qualify to get a good mortgage, like running water, approved septic, possibly built to building code, 3 or more bedrooms, inspection with no sign of rot or insects, good roof, etc. And I only know a little so keep asking them that do know.
Looks like unwanted tillable farm land is at least 4,000 an acre in iowa and illinois.
If the land and house are depreciating assets, then the bank will want to have a HUGE down payment so that you don't dump the property on them when the value goes down. They want to assume zero risk of a loss. Since they have been burned by all the foreclosures *recently*, they remember this and will be less inclined to loan on a house.
Now, if you have a cash-producing business that has a lot of assets, and you are willing to list those assets as collateral, well...have we got a deal for you!!!
Especially if the bank can unilaterally call your loan and then sell what is left to a buddy... Or if you are building, the bank will make you use their designated contractor who owes them money and use your loan to make the bank good while the contractor defaults and you are left with nada.
A saying in Real-Estate is a property is only worth what someone is willing to pay for it.
Give a low-ball offer and see how they react ( I don't know where the property is at)
$1000 an acre is a good price in most places but you are buying a large property so...you have room to negotiate
Why the heck hasn't the SHTF by now
I'm pretty sure it's because 98% of Americans are complete imbeciles. Fat, dumb, happy.
The shit hit the fan 9/11/01. Are you just noticing the smell now?
I'm talking the inevitable fiscal armageddon.
That CLEARLY has NOT happened yet.
This was in the section of the employee manual titled, "Americans Don't Look at This Section"
Fined $1.9 million on (illegal) transactions of $523 million?
That's just a discount (or is it a price)?
DavidC
I believe it's a line item in the budget as the cost of doing business.
It's also tax deductible in many cases. No joke.
As are most legitimate costs of doing business.
Did I say legitimate?
Scotty, never mind tuning those Dilithium Crystals.
I got a new job for you...
Dude.. the $1.9 million fine was on some other scandal, amount of dollars involved not stated. It quite clearly says in the article they paid a $100 million fine on the $523 million business.
Geez, average reading comprehension level and site popularity are apparently negatively correlated.
Frank,
My apologies, you're correct, I shouldn't have been so quick to post!
Nonetheless, <20% fine, it's still worth breaking the law if you only have to pay that amount and no one gets jailed (or gaoled of you want the English version).
DavidC
My social security number is. 321-654-0666
My ATM PIN number is. 9372
The Launch Code is. 1212 Now
.......What's that ? You only
Wanted my birthday.
I, for one, am happy to be a taxpayer in a country that bailed out this bank. It does not take much to see that they have put their ship in order and are operating at a highly ethical level.
/s
Do the crime, pay the fine, avoid the time yet minting dimes...
There is ample evidence to arrest and prosecute RBS executives & managers for sanctions busting. Why the UK Treasury/Regulators and police have not announced any action is a mystery.
Well, actually it is not.
Yes, they don't want to set a precedent, of you know, actually charging bankers with crimes.
The only dumb thing was that the message wasn't verbal.
If you get caught you get a fine; you don't go to jail.
If the fine is large enough that it makes you insolvent, no problem. The governments bails your shiney ass out.
The supreme irony now in the UK is that if any bank was hit with a heavy fine for criminality that forced them into deep doo-doo, it would not be the government (taxpayers) who would bail them out, but investors (ie: anybody who has money deposited in the bank) thru the secretly introduced bail-in Bank Resolution Policy earlier this year, first used by the Co-op bank in May when it suddenly discovered a GBP 1.5 billion black hole in its balance sheet.
In 2016, the EU introduces its own EU-wide Single Bank Resolution Policy which I expect will override the UK's interim policy.
You couldn't make this up.
don't get it. do you disagree with the policy because it's from the EU or because you'd prefer to have further bailouts? it's either taxpayer or depositor, eh?
I have never agreed with taxpayer bail-outs. I do not agree with investor bail-ins.
Both of these reward bad management, criminality etc.
IMHO, the only solution when a bank gets into deep doo-doo is to allow it to become insolvent. The only solution when banksters commit criminality is for those responsible to be shown the inside of the slammer. No exceptions.
Unless and until we deal with banksters the same way as the rest of society, they will continue to cheat and steal. It should be 100% clear that banksters have learnt nothing from the events of 2007-8.
"IMHO, the only solution when a bank gets into deep doo-doo is to allow it to become insolvent"
This is what happened in the past, and the depositors usually lost everything. You can't have it both ways. If banks are going to be treated like any other business when they go bust then the depositors will lose their money because when you deposit money in a bank you are actually lending it to the bank. In a lot of banks the depositors rank below the bond holders. The insurance schemes rely on funding from other banks so if a really big bank goes down it could drag others with it just through the insured deposit scheme. "Bail-Ins" are a new way of describing an age-old phenomenon, nothing new about it at all. If the law is to be changed perhaps a new hierarchy is needed: Managers wiped out first (everyone above branch level looses job and pension), then shareholders wiped out, then unsecured bond holders, then depositors, then secured bond holders.
I agree with your comments about bankers being jailed. The only thing that will start putting us back on the right course will be long prison sentences and confisaction of assets for fraud. No chance of that though. None at all. That is why things are not going to get better.
The Deposit Protection Schemes are intended to protect deposit holders if a bank becomes insolvent and is wound up. If banks were allowed to become insolvent instead of being bailed-out or bailed-in, the DPS applies and would pay out to customers up to a certain level (eg: €100,000 in the EZ and £85,000 in the UK). Customers would therefore not lose their money, although if it was a major bank with a huge number of customers, it would take some time for govt DPS schemes to pay up.
The new EU Bank Resolution policy (bail-in) just agreed and to be implemented Jan/2016 is not the same as the DPS at all. Close examination of it reveals that it not only bails-in depositors instead of taxpayers, but also pre-empts use of the DPS, since the bank won't be allowed to become insolvent. DPS does not cover losses caused by EU or national law under a bail-in policy.
In the same way that if the IMF proposal for governments to apply a flat 10% tax on all bank accounts to solve their sovereign debt crises, this would not be covered by the DPS schemes since such action would be lawful.
Very important, you have to also promise you'll never do it again.
Where do these dumb asses come from? Everybody knows if yoy want to transfer money to a sanctioned country you use bitcoin.
$60 billion thru bitcoin?
A billion here a billion there and soon you're talking about real money. I'm being facetious of course.
So why are they not in Jail?
Because they are a corporation. You can't jail a corporation, you can only fine them. That's how the cocksuckers stay out of jail. Civil Servants under strict orders from their cronies just hit their pocket books (enough to wet their whistles) and look the other way to preserve their jobs and keep the government funded. Corrupt cocksuckers. I've seen it first hand.
Any more blatant or in your face could this be then?
Pay the fine, do no time???
These outrageous bastards have my blood boiling and seething with rage.
Dirty fucking criminal scum, each and everyone of the fuckers who carried this out to the letter. Your day in the peoples court is coming ever quicker with revelations like these you scum fuckers.
Beyond fucking parody.
http://www.alternet.org/economy/bank-fines-and-crime?paging=off¤t_...
When Giant Banks Pay Fines, Where Does the Money Go? Does It Stop Crime?Why do you think they had to be bailed out by the UK government. They are pretty damn stupid and criminal along with it. Somebody should be sent to jail, or at least somebody, ie. CEO and Chairman should be fired. At least they should have the decency to step down.
One day you will wake up and discover your name on a government shit list and regret laughing at a dumb bank skirting "THE LAW" to move YOUR fucking money. Much like "soak the rich" schemes always end up blowing shit all over the ever shrinking middle class.
Better to speak up and be targeted than remain silent and a coward.
.
"it is better to be targeted than not to be targeted."
really?
Does your family agree with you? Does your family want you to be a "target"?
Yes. My family agrees with me. Better to die for a good cause then live to old age with regret and die a coward.
lol. a True Dead Hero.
Better than a live coward. We all have to die sometime, even the cowards.
your Universe is Binary?
Nothing in between Coward and Hero?
I guess the negs mean that
your family will bury you as a hero.
Yet another Dead Hero.
You, are quite the BOOBoo alright. You make it sound like RBS was doing us a favor. What they were doing is breaking the law to enrich themselves. That is what we call crime. When I commit a crime, I get beat down. When a bank commits a crime, they may get a fine that is a small fraction of their ill-gotten profits, which they can then deduct as a business expense. Which bank do you work for asshole?
Oh go fuck yourself ya TOOL, if having your tongue firmly wedged between the ass cheeks of a selective enforcement government makes you sad wait until they show their true nature and plant their boot solely on your pencil neck. If you read into my comment that I some how support this bank or any bank you are a grade A tard. I support the government getting their fucking hand out of my banking matters so pop you mouth off your government tit and pay attention boy.
If we're willing to launch missiles at these sanctioned countries why wouldn't we be blowing up the financial headquarters for these sactioned countries?
like the banks have anything to fear from usa regulators. maybe take some of their candy away and say mean things and hurt their feelings is all.
and they still got their bonuses
STOP DOING BUSINESS WITH THE LARGE BANKS!!!
The sanctions are ridiculous.
Sanctions.
I don't think enough folks realise that Obammy and Wall St. don't have a motivated army to go and enforce santions on anybody any more. They are still puffing out their chests saying -we'll send the gunboats', but there ain't none with a crew.
No one goes to jail and no one is barred from the industry either.
The UK doesn't manufacture anything anymore except banking scandals.
Off topic but color me shocked!
http://www.usatoday.com/story/news/nation/2013/12/12/hawaii-obama-birth-...
The Hawaiian health official who verified the authenticity of President Obama's birth certificate died in a small plane crash.
The plane, carrying a pilot and eight passengers, went down Wednesday in the water a half mile off the Hawaiian island of Molokai, the Maui Fire Department said. The lone fatality was Loretta Fuddy, who has served as state health director since January 2011. Tom Matsuda, the interim executive director of Hawaii's health insurance exchange, confirmed Fuddy's death.
Fuddy, 65, made national news in April 2011 when she verified the authenticity of certified copies of President Obama's birth certificate. Obama had requested the release to curb claims by so-called "birthers" that he was born in Kenya and not eligible to be president.
...
Clean up in aisle 6 bring a mop.
It must be a bitch to have to cover all the lies when your a president.
Geez, back in the day if you held state secrets they at least let you live out your days in an iron mask...
Well at least under the new volcker rule banks can self regulate.
Why doesn't the U.S. simply annul RBS' bank charter and close ALL U.S. operations over a weekend?
Why not extend the sanctions to the offending institutions that are actually the problem?
What is important is that nobody went to jail for breaking the law.
Not in the UK or US maybe but Iceland seem to be getting on the ball.
http://www.bbc.co.uk/news/business-25349240
to what degree of stupidity does it take to make such a noob mistake. brainless people...
Let me guess...no criminal actions. Which, if so, simply makes any settlement/fine a cost of doing business and sure to continue....only next times they will better hide the procedural steps.
I don't care that four employees lost their jobs over this and that RBS essentially admitted wrong doing (though in and of itself is a minor accomplishment).
/sarc on
Corproations are people too, right?
/sarc off
I think I still have an account open from RBS, opened in 1984. I wonder if my 20 quid is still there.
em, just to play devils advocate for a second, and i'm no fan of RBS, who are a very very stupid bank,
But why should RBS, a British Bank, have to comply with US santions,
I already know the answer to this, but the arrogence is just astounding,
Imagine if Iran imposed the same santions on the US, and then got huffy when the whole world didnt comply,
Sanctions are an act of war, and only serve to enhance the power of the target govt,
But why should RBS, a British Bank, have to comply with US sanctions ?
That seems to hit the nail on the head.
It looks to me like half the worlds problems are caused by US foreign policy and the other half are caused by a banking system where crime is actually legal.
Exactly why was it dumb?
a) They got caught
b) They somehow allowed the note to go public
c) They didn't make a profit after deducting the fines
d) All of the above
16th largest bank in world and riddled with Corruption. This Bank should have been split asunder and its senior executives jailed. It is a festering sore and will drag the UK economy into the void. There is no prospect of recovery with this behemoth.
Britain has become a Banker Isle where the whole population is like a flock of sheep being fleeced to provide wool for the Banker Princes and their palazzi. London is Macao and the Uk is Mainland China full of peasants to serve the Banker Elites in their Casinos
So fucking what. Why shouldn't they accomodate payments to Iran or anyone else.
Oh that's right, because Team America said they were evil folks.
Shouldn't the US put itself on that list. After all, their list of war crimes puts every other country to shame.
Q: Problems at home? A: War!
Q: Too much unemployment? A: War!
Q: Obama wants to look tough? A: Try and start a war!
Q: Bored on a Tuesday? A: War!
America, I love your nation, your people are second to none when given a chance to succeed. But fuck me, your "leaders" (both political and financial) are a diabolical pack of self serving cunts. I pray for the day you get a chance to guillotine the fucking lot of them.
Yum, shit sandwich. More please!
Good conspiracy theory.
The lady who signed on Obama birth cert was just killed in a plane crash, 2 years after certifying.
http://sgtreport.com/2013/12/hawaii-dept-of-health-offical-who-certified...
Loose lips sink ships, and dead men tell no tales.
Banks are cons. There is no purpose for banks. They pretty much bribe the politicians so people are forced to use them. They are criminals that are destroying the world, killing people through starvation, war and pestilence. They are scum. pedophiles and must be stopped because they have not the ability to stop on their own. Arrest them. Lock them up. If they are doing God's work then Satan is their master. All they do is counterfeit wealth to transfer your money to them. Somebody call the police.
The bank wasn't stupid, the U.K. was for bailing them out. Same goes on here, too. Isn't it amazing how so many banks have failed and the large criminal banks have survived and thrived? What a freaking scam.
Who's the bigger idiot: The Idiot bank, or the Idiot who keeps doing business with them?
Who's the bigger idiot: The Idiot bank, or the Idiot who keeps doing business with them?
I disagree with your analysis, Tyler. RBS should be nominated for the most honest crooked bank (Mafia Famiglia Award) for the implementation of the reverse-investment business process: collect large payoff now, pay a potential small amount (fine) in the future. Their ROI should be proof enough it's not a dumb bank.
However, I suggest they include the fine amount as a depreciable asset in the balance sheet and expense it under COGS (cost of goods/services sold) in the income statement.