I don't understand the point you are trying to make. The document outlines a pattern of decisions by high level HSBC executives -- ranging from individual tran

I don't understand the point you are trying to make. The document outlines a pattern of decisions by high level HSBC executives -- ranging from individual transgressions such as simply falsifying or sanitizing otherwise illegal transactions, to more long-term choices, such as ignoring basically everyone else in the industry as you mentioned earlier, and systematically under-resourcing compliance departments -- that led the bank to appear to comply with AML laws and regulations when in reality it was flagrantly violating them. In fact, it is a crime to fail maintain an effective AML program if you are a bank, and HSBC does not dispute that they committed this crime. From the document, page 3: 7. The Department alleges, and HSBC Bank USA admits, that HSBC Bank USA’s conduct, as described herein, violated the BSA. Specifically, HSBC Bank USA violated Title 31, United States Code, Section 5318(h)(1), which makes it a crime to willfully fail to establish and maintain an effective AML program, and Title 31, United States Code, Section 5318(i)(1), which makes it a crime to willfully fail to establish due diligence for foreign correspondent accounts.