The U.S. Department of the Treasury made history in December 2012 with the largest collective settlement in the department’s history. The settlement, totaling $875 million, was reached with HSBC Holdings plc (the U.K. holding company of HSBC Bank USA N.A.) regarding alleged violations of the Trading with the Enemy Act and the Bank Secrecy Act (BSA). The announcement comes in the wake of another high-profile enforcement action. The First Bank of Delaware was assessed a civil money penalty of $15 million, which amounted to nearly half of the bank’s total equity capital, for failure to adequately address BSA risk. The bank ceased operation in November 2012.
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