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Following its signing of the DPA in 2012, HSBC embarked on
a worldwide programme of upgrading its compliance
systems to U.S. standards, raising its spending to more than
$1 billion a year. (6)
The DPA itself was lifted in December 2017.
Diagram 1: Comparison of U.S. and U.K. DPAs
Commenting on the expiry of the DPA, Gulliver said
improving compliance would “remain a top priority for the
bank into 2018 and beyond".
