>The relevant text is: "17. From 2006 to 2009, HSBC Bank USA knowingly set the thresholds in CAMP so that wire transfers by customers located in countries categorized as standard or medium risk, including foreign financial institutions with correspondent accounts, would not be subject to automated monitoring unless the customers were otherwise classified as high risk."
It's very misleading to leave out the "unless the customers were otherwise classified as high risk." That smacks of someone not understanding how to properly implement the compliance function.
I don't see anything misleading. It clearly shows this was no negligence.
They purposefully complied only for the coarser and more dangerous cases ("customers classified as high risk") and stood to benefit for letting all the others go through.
It's very misleading to leave out the "unless the customers were otherwise classified as high risk." That smacks of someone not understanding how to properly implement the compliance function.
I don't see anything misleading. It clearly shows this was no negligence.
They purposefully complied only for the coarser and more dangerous cases ("customers classified as high risk") and stood to benefit for letting all the others go through.