While the US settlement requires the bank to make improvements on its compliance controls, Goldman managed to avoid any obligation of having a government-appointed monitor to oversee its compliance department, which had been an earlier priority for prosecutors and would have added enforcement heft to the probe’s resolution.
“I would have insisted on having this imposed on Goldman,” said Rodriguez Valladares. “Having an independent outside monitor could expose weaknesses in their controls in multiple areas of the bank. Without an independent monitor, regulators and investors will never know all the details of how Goldman got away with this scandal.”

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