Deferred prosecution · $1.92B HSBC — Too Big to Jail
In 2012 the British banking giant HSBC entered a deferred-prosecution agreement with the US Department of Justice, admitting it had failed to maintain an effective anti-money-laundering program. The failure let Mexico's Sinaloa cartel and Colombia's Norte del Valle cartel launder at least $881 million through the bank; a US Senate Permanent Subcommittee report described a "pervasively polluted" culture and found HSBC's Mexican unit shipped about $7 billion in physical cash to the US in 2007–08. The cartels reportedly designed boxes sized to fit HSBC's teller windows for the volume of cash. HSBC paid $1.92 billion — the largest such fine at the time, but roughly five weeks of the bank's profits. Crucially: rank-and-file prosecutors had prepared up to 175 charges, and no executive or employee went to prison. A 2016 House report later concluded Attorney General Eric Holder had "misled" Congress and that officials declined to prosecute over financial-stability fears — the "too big to jail" doctrine, foreshadowed by the near-identical 2010 Wachovia cartel-laundering settlement. The admission and the fine are on the record; so is the absence of any individual accountability.