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While U.S. officials periodically have announced plans to more frequently punish individual bankers involved in institutional violations, the practice has long been the norm in Switzerland, where the country’s chief banking regulator can use a variety of mechanisms to pursue employment bans against responsible parties.

Recent months have seen the Financial Market Supervisory Authority, or FINMA, more frequently issue private letters to Swiss bank executives who have resigned amid financial scandals, notifying them that they have been placed on a “watch list” and cautioning them to first notify the agency before going back to work in the financial sector, prominent Swiss attorneys contacted by ACAMS moneylaundering.com said.

Meanwhile, bankers who opt to remain in their current roles despite their alleged involvement in anti-money laundering violations and other malfeasance are also more likely to face administrative proceedings that fall short of criminal charges, but could result in a maximum ban of five years from the industry.

The apparent uptick in both types of individual enforcement actions in Switzerland has compelled many Alpine bankers to prioritize compliance with AML rules and other controls against financial crimes, according to Mark Pieth, a criminal law professor at Basel University.

“There’s a real risk of being kicked out,” Pieth said. “They’re pretty scared.”

Yet FINMA’s apparently dogged approach towards individual accountability may also reflect its limited range of enforcement tools. Unlike their American counterparts, Swiss regulators do not have authority to levy large-scale fines against financial institutions for sanctions and AML-related violations.

FINMA can order a “disgorgement” of profits derived from illicit activity, but those sums tend to be a mere fraction of the total amount suspected of being laundered.

The regulator only disgorged $6.5 million from Coutts & Co Ltd. in February after finding that the lender failed to properly scrutinize accounts linked to 1MDB, but acknowledged that that the tainted funds flowing through private lender’s accounts in Switzerland totaled about $2.4 billion.

In 2015, FINMA investigated a total of 29 domestic financial institutions on suspicion of violating AML rules, though not every case led to an enforcement action, FINMA chief executive Mark Branson said in an April 2016 press conference.

Sixteen Alpine banks were the subject of enforcement actions “in the last few years,” and six of those ran parallel to investigations of individual bankers at those institutions.

Yet Branson also said in that between 2009 and early 2016, the regulator has initiated “administrative proceedings” against “close to 30” individual bankers, SwissInfo reported.

FINMA spokesperson Vinzenz Mathys more recently estimated that within the past five years, the regulator has imposed bans against six bank managers and initiated administrative proceedings against six others.

Switzerland, whose 300 or so banks together hold nearly a quarter of the world’s $10 trillion in offshore assets, has worked for years to counter its reputation as a nontransparent jurisdiction but remains at the center of several high-profile illicit financial schemes, including those involving state fund 1Malaysia Development Bhd. and Brazilian firms Petrobras and Odebrecht.

Going after individuals carries an “important deterrent effect” whereas “a pure punitive fine is announced today, paid tomorrow, and in the recycling heap of newspapers the day after,” Mathys said.

FINMA’s authority to launch the proceedings originates from the Swiss Federal Act on Banks and Savings Banks of 1934, which requires senior bankers to maintain a “good reputation” and conduct themselves with “irreproachable conduct”-which the regulator interprets as covering a range of compliance failures.

The majority of recent administrative cases were launched in response to alleged AML-related failures, according to Douglas Hornung, an attorney with DH Avocats in Geneva who recently represented an individual under a preliminary investigation by FINMA.

Hornung’s client, the former head of a foreign lender’s branch in Switzerland, received a letter from FINMA after the institution failed to conduct adequate due diligence on a wealthy customer.

The client was ultimately cleared of any wrongdoing after demonstrating that a former supervisor had been warned of the risks posed by the relationship, Hornung said, adding that the supervisor was then sanctioned for the decision.

“Even for these so-called smaller employees inside the bank, who really did everything they had to do, they may be in big trouble,” said Hornung, who said his client was unable to start a new job at a different lender during the four months it took to contest the preliminary investigation.

The correspondences do not always include details of the allegations against the bankers who receive them, and there historically have been few, if any, legal avenues for appealing against them.

“Practically speaking, you are out of the market” after receiving a letter, according to Carlo Lombardini, an attorney with the Poncet Turretini in Geneva.

A recent decision by the Federal Supreme Court of Switzerland suggests that will change, and thus complicate FINMA’s use of the watch list.

On March 22, the court ruled that a former UBS employee who was placed on the watch list could have his personal information deleted, and that additions to the list must be based on “serious” and “rigorous” information.

The decision confers bankers the right to request the justifications for their inclusion on the list and petition for their removal, Hornung said.

The regulator also has authority to refer minor cases to other departments. Swiss bankers who fail to report suspicious transactions, for example, could face a separate “minor criminal offense” proceeding overseen by the Federal Department of Finance that could end with a conviction.

FINMA’s recent approach to enforcement represents a marked shift from years past, when the chief executive of a bank under scrutiny could travel to the regulator’s offices in Bern and resolve the problem in a closed-door meeting, according to Enzo Caputo, a Zurich-based attorney.

“The Swiss mentality is not one of confrontation,” he said.