As the Standard Chartered chairman, Sir John Peace, was obliged to remind us the other day, the bank accepts responsibility for "past knowing and wilful criminal conduct" in violating US economic sanctions.
The cost of settlement with the US authorities was £415m and the damage to Standard Chartered's reputation is still being counted.
It should have been a straightforward matter, then, to claw back bonuses from senior executives. The violations took place between 2001 and 2007 but Peter Sands, today's chief executive, was finance director for most of the period and the current finance director, Richard Meddings, was a group executive director responsible for risk.
But no – not a penny is being recouped. The financial penalty was simply thrown into the mixer with all other factors determining the bonus pool.
Ruth Markland, chair of the pay committee, explains that she and colleagues "carefully considered" whether "the circumstances were appropriate" to claw back past awards. But they decided they were not. She then adds that income and profits from "the matters that were the subject of the settlements" were immaterial and thus did not inflate prior bonuses.
Markland and her committee are being feeble. Look, the bank has just paid out £415m for actions that it admits amounted to criminal conduct; it is irrelevant whether or not profits were generated. This decision is lofty, short-sighted and will reinforce the impression that Standard Chartered is still in denial about the gravity of its offences.
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