I think its true that in general private sector firms really do care about reputational risk, dont want to deal with people that are involved with illicit finance. I think its also true that the work of tfi over this last set of years and sort of putting up the mirror and reminding people of this proposition and reminding them that theyre watching and that there are consequences to people who are insufficiently attentive to this set of things has been critically important in both reminding folks and sort of heightening their sensitivities because its not every private sector actor, certainly not globally. Certainly not in geographies, you know, near and far, that have over time given this sufficient attention. I think its the combination of it being in the economic interest of private sector entities and the work that tfi, david, and stewart, their colleagues, and others in the u. S. Government have done to help keep that kind of in the top of consciousness consistently that has been the sort of twin pieces of getting the advantage from the private sector in this regime that stewart i think spoke very effectively about earlier today. Let me take from that point and ask the question, and its a fair one mplgt fair one. I get it outside when i go out and do talks and things. How can we talk about the importance of the private sector the integrity of the system, when you see so many examples of banks failing and getting hit with enormous fines . Are we talking about two different narratives . How do you square that circle or is it part of the same story . Well, first of all, i think private sector have lots of different objectives and lots of competing goals, so although they want to be compliant, they also want to, you know, make good returns for their shareholders, and i think sometimes those things tend to be i think there can be a tension between the senior most officials at some of the entities who have kind of a broader view, perhaps a greater capability of being able to see all these different dimensions and coming down in a place that we would think is integrity laden and folks, you know, within very farflung, very decentralized, very complicated institutions, and i think, you know, compliance with these regimes doesnt come with the snap of a finger. Ruben talks about 100 page manual, but, you know, in some of the institutions they are doing business in 150 or 180 or, you know, almost 200 different geographies. Its a complicated business. I think companies have gotten themselves on the wrong side of this regime with greater frequency than we would like. I think thats part of, you know, tfi does prophylaxis. Lays out the rules, hopefully with a lot of clarity so people can understand them and follow them effectively. They do monitoring, and then they do expost enforcement when thats appropriate. I think its all those pieces that together make an effective regime in this area because, you know, some people get it right at the beginning. Some people want to get it right but dont, and then, you know, the world is full of bad actors in all kinds of places, and some people have other objectives in mind. Ruben, can you feed off of that, and also maybe give folks a sense of where you have seen an example or two of the private sector capitalists around these issues, around the issues of compliance and what that balance looks like . I dont think theres any between tone at the top and what gets permeated throughout the organization. In any big Global Financial institution, you are talking tens of thousands of people at many of the large Banking Institutions around the world. Theres no substitute for setting the right tone at the top. Ethics, training, procedures, et cetera. That said, there are going to be mistakes. There are going to be commercial judgments made that look reasonable at the time, that could be mistakes. Its ultimately balancing. One of the important aspects between the relationship of the private sector and governmental institutions involving creating these rules, implementing and entoe enforcing them is a sufficient degree of trust, transparency and communication. They are always going to be somebody mine once said that no matter what you do in any large organization, the leadership is probably always going to be someone who is making a bad decision somewhere that could come back to hurt the institution institutionally, but there has to be essential trust where in legitimate circumstances, there are incentives to report, there are incentives to remediate, and the punishment is calibrated to fit the crime, as it were. There are also situations where there is a legitimate clash of strongly felt and important policy interests. One of the case studies in this area. Money transfers in somalia, where you have two purposes that seem to be irreconcilable for the banks at issue. One is cracking down on any risk of terrorist financing flows to illicit actors, and i think its fair to say that history has shown that there are probably one or two of those hanging around in somalia and various places. And the other is the important crucial humanitarian concern that remittance flows make it to disaffected, impoverished populations of innocent people on somalia who rely heavily on flows from friends, relatives, and others who are working out of the country. The Ngo Community raises they their hands and many politicians say, write a second, you cant 99 of these people are total innocents. You cant just cut it off. Its a great example of kind of if only it were academic. Its the real world of the extreme case where you get direct policy trade, two laudable, important but conflicting objectives. I think its a critical point and a question that goes along with some of the themes we heard earlier in the day about the potential over use of these tools and perhaps even the burdens on the private sector. Feeding off what your example was, ruben, have we do you think weve reached a Tipping Point perhaps where were asking the private sector to do too much and where the derisking thats happening in some of the institutions are affecting, as you said, some of the Public Policy principals of Financial Inclusion, which may be in direct opposition to the tools of the financial exclusion, which is the sort of stock and trade of tfi. What do you think about that . I think this is a subject that bears lots of continued scrutiny. Its hard to answer these questions at a conceptual level. I dont view the sort of the regulatory imperatives with respect to Money Laundering or lots of others that the u. S. Government in other guises imposes on the private sector, in particular the Financial Sector as being kind of inhermitly and, you know, in conflict with a set of policy objectives like Financial Inclusion. So, for example, in some of the circumstances and, you know, without the specific reference to the somalia example that ruben gave, there will be some space open for some Financial Institution that, you know, has the right Compliance Regime and observes the right integrity principles to have an economic incentive to go fill that space. In some cases in somalia it might be this case. That wont be true. There isnt enough financial incentive to go down that in the private sector. Then you seed another set of possibilities. Whether thats governments or nogst ngos or a set of things. In no case does it strike me as its an impossible thing to think that you can provide Financial Assistance to these populations. Even those that have lots of complexities and that are that will allow people to have access to Financial Services in some fashion or another, allow them to live their lives and do things that we think are important in other respects, but also make sure that the bad guys arent taking advantage of access to a Financial System that we think has other problems associated. I kind of resist the idea of it being zero summed, but i do acknowledge that in any one of these particular contexts, the exact solution, the way to sort of figure out the rubiks cube of that circumstance can be difficult. I think you have to keep in mind that theres been a substantial evolution of tfi since 9 11 really. The first actions immediately after 9 11 and the tfi initiative. Then it gets a little bit some of the initiatives get conflated with doddfrank and additional regulatory measures taken to shore up, protect the Global Financial system post the financial crisis. Going through the evolutionary phase, and the devil is in the details. Neil is absolutely right here. Its hard to talk about this conceptually. We have to take stock of the whole of a lot of rules, regulations, that are out there, and look at given the benefit of experience, whats still a work in progress, et cetera. Of whats working, whats not, what are the cost and benefits, et cetera. Another example, announcements its going to cut off activity to socalled politically exposed persons. Whats that all about . And the question from a policy standpoint, is it better to have them do that or work with the guys that are bad actors in ways that have some transparency visibility. Theres a lot of theres a lot of actions that Financial Institutions are taking in response to various regulatory measures that i think need to be were sort of at that second wave. Its like michelle talked about earlier on the intel bill where you have to step back away from the furor of media, lobbyists, all that and sort of say, okay, what makes sense here . What doesnt . Where are the tradeoffs . I would say two of the things on your Tipping Point question, one that i think my perspective is an important thing about. One is that theres an argument out there that the more regulatory focus is placed on the big Financial Institutions. The likelier it is that whatever bad activity is going to migrate to other places, its a little like chasing the spotted monkey around the table and to some extent thats absolutely true. Meaning, you know, bad actors will find the sort of weakest places in the system and presumably try to exploit it. To me thats not an argument that were over doing it on the big Financial Institutions. Thats an argument for figuring out, and its not necessarily easy. Tfi has been working at it get better and better at it, but i think thats going to be an important part of their just to use dennis metaphors, the next ten years to try to figure out how to bring some essentially equivalent set of regimes to other parts of the Financial Sector that are smaller, less formal, less interconnected for which, you know, having the capacity to say, you know, dollar clearing at the new york fed is sort of the key lever and so thats going to be a complicated business. The second something, i spent a little bit of time in the government on Financial Regulation more generally. You know, you hear globally this is too much and its going to put u. S. Firms as a disadvantage relative to their competitors elsewhere. I think my natural reaction to that and the reaction that tfi has brought and the treasury has brought more generally is thats not the right way to think about it. They should come the rest of the world should come up to our standard, and tfi and the treasury in other domains has spent an awful lot of elbow grease trying to do just that and being quite successful at doing just that, rather than dumbing down our own regime in a way that makes the whole thing less robust, and it connects back, of course, to where you started, juan, which is that its not for academic reasons that were putting all these Different Things in place. Its got a Huge National security component and a huge component that relates to the integrity and proper functioning of Financial Markets in the u. S. And therefore globally. Let me take you back off that and make ask a couple questions related to challenges and limitations. These tools has animated the ability to cooperate. Are we seeing, though, in the enforcement environment, especially with major foreign banks getting hit with multibilliondollar fines, are we seeing a moment where some of these measures are beginning to complicate diplomacy or to change dynamics in a way that we havent seen in the last ten years . I guess it depends on what you mean. Just to take stuarts actual example, then ill broaden it out to your question, juan. There ought to be more cooperation in the area of data sharing as between the government and private sector entities, and i think thats the right objective. Its laud able, its important and theres a lot of potential benefit from it. On the other hand, its a complicated business. The government operates in a broadly classified world, or at least tfi does. That creates a lot of challenges for the government in thinking about how and what to share with the private sector. And adversely, the private sector thinks of all their data in large number as a proprietary set of things. Dont want the government poking around in it. Dont want the possibility that some committee of congress is going to get ahold of it, quite keen to keep it close to their vests. So youve got these two broad dynamics that work in opposition to stuarts aspiration, which doesnt mean we shouldnt continue to focus on it, but its hard. I think on the broader side of things about enforcement measures the following. In our country, anyway, Law Enforcement doesnt sting and it does it on its own. I dont know if thats good or bad, but the basic judgments about prosecution and enforcing the criminal laws in the United States are made by Law Enforcement officials and not by the rest of the government. I think that, you know, its a good thing that when Financial Institutions or anyone else, for that matter, do things that are in violation of our law or someone elses law there be consequences. I dont think thats very complicated. I think to some extent what we see now is a heightened appetite or an increased willingness for Law Enforcement officials both at the federal level and the state level to do things that heretofore they have some skittishness about, particularly in the midst of and immediate aftermath of the financial crisis, but i think their appetite for this sort of thing is obviously ticked up. I think for all these institutions, it remains the case you know, in some sense rubin is very situated, and stuart, who sits in one of the worlds biggest Financial Systems, i think its absolutely the case that the u. S. Is the irreducible, unavoidable place where one needs to do business, because our economy is the biggest and most important and, you know, its both a reason why these firms need to get their act together more than ever before. And i think it also has a certain, you know, deterrent effect to being a little loose at the joints. And ultimately theyre going to have to think of it if they dont think of it that way, theyll have to think of it as the cost of doing business, which is not the preferred way, but none of them will leave the u. S. Economy, as far as my eye can see. Its unthinkable. Too much opportunity here, too important both from an Economic Perspective and from a Financial Markets perspective. So although its true that, you know, a series of Law Enforcement actions have gotten a lot of headlines and mean certain things to the people involved, it really hasnt changed the basic realities of how and why and whether theyll engage in the u. S. Economy and the u. S. Financial markets. Rubin, before you go, on this question of diplomacy complication or not, i do want to get to the conversation about what this means for the role of the dollar, et cetera. I wanted to follow up on your point about Law Enforcement. Are we at a point where the department of justice or state authorities, regulators or Law Enforcement, are now driving the systemic debate . In some ways, are the next ten years going to be a discussion about the role of Law Enforcement and regulators, and should there be more of a hand, for example, from treasury in thinking through the systemic impacts of Enforcement Actions . The church thinks a lot about the systemic applications of everything. Thats kind of what theyre paid to do in large measure. I think in our country again, Law Enforcement decisions, decisions whether to prosecute on a continuous basis, is given over to the federal department of justice and a range of state Law Enforcement entities. I think thats a good thing. I think the long history of this in the u. S. Is that we dont want our judgments about criminal prosecution to be affected by politics or by other kinds of considerations. Hopefully those folks are thinking about systemic implications of their Law Enforcement activity. They ought to be thinking about charging decisions and whether to go after this target or that target, they ought to be taking kind of a whole range of things. But i dont think it changes the basic dynamic. It has always been the case that the Justice Department at the federal level has been in charge of criminal enforcement. And the regulators and in the case of sanctions and Money Laundering, theyve been at the core of Financial Institutions regulators. The civil side enforcement and the actual, you know, carrying out of the administration of these sanctions regimes, i dont think that dynamic changes, and i can assure you that