
In 2012, HSBC was fined $1.9bn and entered into a Deferred Prosecution Agreement for facilitating the laundering of money by the Mexican drugs cartel headed by Joaquín “El Chapo” Guzmán. The US Justice Department had been all set to bring criminal charges against HSBC executives and seek jail terms but was persuaded to strike a deal instead.
One of those who had been at the Justice Department and had paid close attention to what was unfolding was Richard Elias.