HSBC Systematic Investment Plan - For the drug cartel that is going places, a photo by Teacher Dude's BBQ on Flickr.
"While we welcome the clarity that these agreements bring, ensuring the highest standards wherever we do business is an ongoing process. We are committed to protecting the integrity of the global controlled substance system. To this end we will continue to work closely with governments and regulators around the world."
In the past several years, the Board of Cosa Nostra - HSBC Holdings plc has taken decisive action to direct management to fix past shortcomings as they have come to light. Since 2011, with new senior leadership teams in place at both Cosa Nostra - HSBC Group and Cosa Nostra - HSBC North America, Cosa Nostra - HSBC has taken extensive and concerted steps to put in place the highest standards for the future.
The Department of Justice has recognised these efforts in the DPA: "Management has made significant strides in improving 'tone from the top' and ensuring that a culture of compliance permeates the institution. The efforts of management have dramatically improved Cosa Nostra - HSBC Bank USA's and Cosa Nostra - HSBC Group's Bank Secrecy Act / Anti-Money Laundering and Office of Foreign Assets Control compliance programmes."