Page 153 - Bank Case Studies

Deferred Prosecution

Agreement

A Deferred Prosecution

Agreement (DPA) is an

agreement between a

prosecutor and an

organisation which could be

prosecuted, under the

supervision of judge.

The agreement allows a
prosecution to be suspended

for a defined period, in the
case of HSBC for five years,

provided the organisation meets certain specified
conditions. If it failed to meet these conditions the bank

could face severe repercussions. Potential penalties

included further multi-billion-dollar fines or having its US

banking licences withdrawn, which would have crippled the
bank.

The DOJ had appointed a former New York prosecutor to
independently, monitor HSBC’s anti-money laundering

programme at a cost of $200million a year (until July 2017)

thereby tightening up its compliance procedures. and has a

workforce of more than 6,000 people dedicated to ensuring
they are adhered to.