you seem to be mixing up reporting regulations with the "we both know you did something shady but it was likely not explicitly illegal back then, so let's not g

you seem to be mixing up reporting regulations with the "we both know you did something shady but it was likely not explicitly illegal back then, so let's not go to court and waste each other's time, but let's never try that, and for this courtesy you pay us a few billion USD, mmkay?" deferred prosecution agreements. reporting regs are clear (clearer at least) than the other stuff.