The "unsafe and unsound banking practices" specified in the agreed order included:

• Conducting transactions with high-risk countries without the appropriate risk management procedures in place.
• Failure to supervise a specialised division, allowing inadequate due diligence, especially for high-risk countries.
• Failure to follow appropriate documentary and record-keeping requirements.
• Failure to adequately train employees to identify and report suspicious transactions.
• Failure to maintain an adequate system of internal controls to monitor and report suspicious activities.
• Failure to monitor the activity of loan accounts for unusual or suspicious payments.
• Inadequate identification and monitoring of accounts of Politically Exposed Persons (PEPs) who conducted business with the bank.

The bank neither admitted nor denied the allegations, which apparently took place between 2001 and 2004.