Lol. > Bernhardt alleges that HSBC evaded the OFAC filter beginning in the early 1990s and continuing through 2009. HSBC Bank UK implemented procedures to hel

Lol. > Bernhardt alleges that HSBC evaded the OFAC filter beginning in the early 1990s and continuing through 2009. HSBC Bank UK implemented procedures to help sanctioned entities access and benefit from U.S. financial services. For instance, such entities would include a “cautionary note” in their transactions, such as “care sanctioned country,” “do not mention our name in NY,” or “do not mention Iran.” Based on these notes, HSBC Bank UK would manually scrub all references to Iran or a sanctioned entity, which would allow otherwise illegal transactions to pass through to HSBC Bank US. This system allowed HSBC Bank US to “process[] thousands of ‘repaired’ transactions worth billions of dollars.” HSBC Bank UK would also use “cover payments,” or bank-to- bank transfers, to avoid disclosing the identity of its customers.