Umm yes they were, even if they'd done everything right. Look at the HSBC case and tell me the bank did anything nefarious or even negligent. Nope, governments hit them both ways.
HSBC admitted negligence. The cartels liked working with HSBC so much they even had secure money boxes made that were specifically designed to fit through the hole in HSBC branch teller windows.
There are tons of references online, but these are some:
Second link: they kowtowed to Congress because it would be worse if they hadn't. Look at what they actually did: they complied with the law and advised their clients on how to comply with the law. That's their job.
Third link appears to be all about allegations in a lawsuit rather than anything that was proven.
