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HSBC, $1.2 billion. JPMorgan Chase & Co., $2.6 billion. BNP Paribas, $9 billion. Dozens of U.S. enforcement actions and prosecutions initiated in recent years in response to anti-money laundering and sanctions-related violations are all at least partially predicated on the same mistake: financial institutions deciding to onboard lucrative, but unacceptably high-risk clients over the objections of their compliance departments. Subsequent blame for these expensive mishaps is often laid at the feet of see-no-evil, hear-no-evil boards of directors; overruled or even cowed compliance officers; and, of course, the orchestrators of the original sin: shortsighted wealth relationship managers and private bankers who...