Globally, fine amounts have edged up following a massive
fall from the peak of the big benchmark manipulation cases in 2013
and 2014. This in large is dominated by U.S. enforcement
actions.
Of the large fines globally included in the scope of this
research, fines against firms increased from US$19.7 billion in
2015 to US$25.9 billion last year. For the first six months of
2018, meanwhile, the total was US$8 billion.
That, though, obscures a more complex picture. First, the
overall figure is heavily influenced by activity of the U.S.
regulators. In 2017, the U.S. accounted for US$24.4 billion of the
total, an even higher proportion than usual. Moreover, this figure
is itself skewed by some large fines in bribery cases against
non-financial firms; AML and fraud cases against financial services
firms; and other fines relating back to the financial crisis cases.
Even more significantly, two extremely large fines (relating to
disclosure and client communications)
