Everyone here seems really eager to take the DOJ at face value. Wow. Quite a reversal. In order to get anywhere, the DOJ has to charge HSBC with willful violat

Everyone here seems really eager to take the DOJ at face value. Wow. Quite a reversal. In order to get anywhere, the DOJ has to charge HSBC with willful violations. So of course the government alleges that the violations were willful. Everyone here seems perfectly willing to accept those accusations, and every allegation in the DPA, regardless of the level of evidence presented in court. The knee-jerk reaction here seems to be that if someone running a corporation is alleged to have a subpar compliance program, it's all part of a giant willful conspiracy. This DPA raises the interesting question of what constitutes sufficient AML/KYC compliance. Fine. It looks like HSBC had a subpar program, which is illegal, even though there aren't precisely defined standards for AML/KYC in terms of what's adequate at scale. But people here are still really eager to criminally prosecute people for failing to prevent money laundering. This is hugely different from knowingly helping drug cartels, which is what HSBC is being accused of in the media.