Requires HNAH to take corrective action to improve its firm-wide compliance risk management program
This document appears to be page 22 of a report by the consulting firm Protiviti, prepared for the House Oversight Committee (indicated by the Bates stamp HOUSE_OVERSIGHT_024128). The text outlines historical regulatory failures regarding Anti-Money Laundering (AML) and the Bank Secrecy Act (BSA) at HSBC and Citibank. It details Cease and Desist orders issued by the Federal Reserve and the OCC in 2010 and 2012, citing deficiencies in monitoring suspicious activity, wire transfers, and foreign correspondent banking. While part of an investigation file often associated with Epstein (likely the Deutsche Bank investigation), this specific page focuses on the regulatory history of other major banks as context.
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