Findings · 11 of 16

Penalties track ability to pay

What it is

The size of a fine repeatedly reflects the company's financial position or the regulator's statutory authority rather than the scale of injury.

Why it matters

Headline penalty numbers are a poor proxy for how serious the underlying conduct was, and an even poorer proxy for whether anything changed afterwards.

Companies and rows it touches

British Airways: ICO announced ~£183M intention, imposed £20M (an ~89% reduction, driven by pandemic-era finances). TJX: FTC settlement carried NO fine at all because the FTC lacked civil penalty authority under the FTC Act. Emirates: Italy's Garante fined EUR 180,000 - a filing fee at that company's scale. Texas v. Google: $1.375B, but Google admitted nothing and was required to change NO product.

Where to look

Global Airlines (British Airways, Emirates); Retail & Fintech (TJX); Productivity & Comms Apps (Texas v. Google cross-reference)