We've been hearing for some time that enforcement actions issued by regulators are guides for banks to learn what not to do wrong at their institutions, but they're not necessarily instructions for what every bank should do.

"Just because we've instructed a bank to take an action doesn't mean that that's an action every bank should take," said Anne Jaedicke, Deputy Comptroller of Compliance for the U.S. Office of the Comptroller of the Currency, at the Seven Deadly (AML) Sins panel.