= Failure to conduct monitoring of the high volume of monetary instruments through casas de cambio and other foreign correspondent customers using Remote Deposit Capture (RDC) service « Failure to monitor sequentially numbered traveler's checks used by casas de cambio and other foreign correspondent customers in a manner compliant with internal policy on these transactions » Failure to institute appropriate risk-based monitoring of foreign correspondent banking customers — primarily as a result of setting alert parameters based on staffing capacity » Failure to file timely SARs on several foreign correspondent banking customers » Failure to report cash structuring activity o HSBC: In October 2010, the Federal Reserve Board announced that it had issued a Cease and Desist Order between HSBC North America Holdings, Inc. (HNAH), New York, New York, a registered bank holding company (BHC), and the Federal Reserve Board. The order requires HNAH to take corrective action to improve its firm-wide compliance risk management program, including its anti-money laundering compliance risk management. Concurrent with the Federal Reserve Board's announcement of its enforcement action, the Office of the Comptroller of the Currency announced its issuance of a Cease and Desist Order against HSBC Bank USA, N.A., McLean, Virginia (HBUS, a subsidiary of HNAH), for violating the Bank Secrecy Act and its underlying regulations. HSBC was directed to use its financial and managerial resources as a source of strength for its bank subsidiaries, and in particular HBUS, to ensure that it complies with the OCC Consent Order regarding HBUS' BSA/AML program. It was also directed to “retain an independent consultant acceptable to the [Chicago Federal] Reserve Bank to complete a review of the effectiveness of the firm-wide BSA/AML Compliance Program adopted by HNAH (the ‘BSA/AML Review’), and to prepare a written report of findings and recommendations (the ‘BSA/AML Report').” In another section of th