Banks may be too big to fail but their employees, apparently, aren’t too small to nail.

After taking a boatload of abuse during Senate Banking Committee hearings in December that no individuals were held civilly or criminally liable for the HSBC violations, OFAC has started waving a big stick at bank employees who might play some role in sanctions violations

As reported by Brett Wolf at Reuters, Treasury spokesman John Sullivan had this to say last week:

Although sanctions enforcement cases involving financial institutions have typically concluded with civil penalties at the corporate level, individuals can and do face liability … when they are personally responsible for sanctions violations, and Treasury’s Office of Foreign Assets Control will take appropriate enforcement action in these circumstances.

Of course the issue here will be which employees will be “personally responsible” if illegal transactions for Iran are cleared by a bank. Are we talking about the people in the wire room who process the transactions or are we talking about the folks with keys to the executive washrooms? I am probably not being overly cynical to suggest that it will be the wire clerks and not the VPs who will pay here.