Carl Levin

It is fair to investigate and prosecute targeted organizations unacceptable.

The oversight function is critically important and that is our responsibility, to bring about accountability through oversight.

I agree with that and I also agree that Congress has responsibility, too, in our oversight.

Why should banks open accounts for bearer share corporations?

Now, another article of the consent order required that the bank retain one or more independent consultants to conduct an independent review of account and transaction activities.

Are the bank's deficiencies in how it is monitoring for suspicious activity a problem as far as the OCC is concerned?

So the exams are going to be considered this year when assigning CAMELS management ratings?

It is important that line of communication be kept open, that people be able to appeal denials of their strong urgings after notifying their supervisor that they are going to do it.

Is the revised approach going to have some sort of thresholds that they are going to apply, maybe to different time frames, such as how many MRAs in a month, how many MRAs in a year, and so forth?

So, Mr. Curry, this was not a case where OCC examiners failed to do their job, by the way.

I was very concerned.

We hope this visibility will actually help reform efforts at the bank.

A number of money laundering problems identified by the OCC in 2010 related to inadequate monitoring for suspicious activity.

That is really a step forward.

This is pretty feeble enforcement.

Now, sharing information across international lines is not just an ancient problem at HSBC, it is still a current problem.

Well, when you say what you are legally permitted to do, were you legally permitted by the Caymans, by their law, to provide this?

Presumably, it will be caught by the same mechanism being applied in every one of your banks, wherever they are located.

I mean, a lot of things are unacceptable. But on degrees of unacceptability, is this not kind of shocking?

You made reference to your service with the U.S. Government. If I remember, you were the Under Secretary of the Treasury for Terrorism and Financial Intelligence. Do I have it right?

I just do not understand it.

So as Exhibit 55 says so simply and eloquently and dramatically, your own people 'were being asked to `fudge' the nature of the payments to avoid the U.S. embargo and seizure.'

I was really angry to find there had been an audit report on these in the previous year, but that it had been closed off with no action.

These were problems which were known for years. This is not something which was looking back.

Will you give us for the record the status of that effort?