The Panama Papers leak continues to resonate across the globe with revelations, both salacious and otherwise, about the hiding of vast sums of wealth through shell corporations. One of the fallouts from these revelations has been the bank counterparties involved in the worldwide shell game to hide assets—both ill-gotten and legitimate. For even if a shell company is created, the money must be laundered somewhere by someone. That someone is usually a bank. 

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...