Deutsche Bank's business is to facilitate financial transactions. They are not an arm of the government and their job should not be catching criminals. Imagine if a pharmacy was held liable for selling prescription drugs to clients who hold valid prescriptions. Unfortunately, banks are increasingly required to play this role, and this is not in the best interests of their clients. Thanks to FATCA, foreign banks already regularly refuse to serve American expats abroad. The end game of all this will be increasing fragmentation of the international financial industry and higher costs for cross-border commerce and trade.