Here are the FinCEN charges, and my reading of the answers, using only what is within the four corners of the audit report to formulate conclusions:

• The legality of the business backgrounds of a number of BDA's customers, the North Korean entities, is called into question.

BDA did not have in its records a sufficient amount of documentation to confirm the legitimacy of the bank's North Korean customers.

• BDA's business with North Korean entities forms a significant part of the bank's business.

This appears to be TRUE, taking the audit's conclusions as correct.

• North Korea pays a fee to BDA to allow access to the banking system through BDA.

TRUE.

• The bank accepts deposits of precious metals which constitute the bulk of North Korea's precious metals sales.

This appears to be TRUE, though we do not have independent verification. (of course this is presently impossible with respect to North Korean financial transactions outside of BDA)

• The transactions that FinCEN questions, being several multi-million dollar wire transfers for a North Korean Company related to alleged criminal activity, and multi-million dollar cash deposits and withdrawals for North Korean agents, give an indication as to the materiality of the questioned transactions. (over $2m transactions).

TRUE.

• The bank continues to maintain a relationship with a North Korean front company, despite the fact that the company's head was charged with depositing counterfeit money.

This appear to be TRUE, notwithstanding that the copy of the Audit we have is redacted, and names of individuals and companies have been deleted.

• The bank is accepting and putting into circulation large numbers of counterfeit currency notes.

TRUE, but the volume of counterfeits does not appear to be as high as the US claimed.

On balance, Banco Delta Asia was found to have ignored the compliance function, allowing a significant  North Korean access to the global financial structure, without a vetting of either funds or clients. Though much of the details are still unknown, due to the lack of documentary evidence and the conspicuous absence of any meaningful due diligence/source of funds enquiries. There is a total and complete breakdown of the compliance function, and it appears from the report that BDA simply chose to follow neither minimum standards, nor its own internal requirements.