HSBC has had to mend its ways, avoid committing any kind of offence while on probation and pay penalties and forfeits of $1.9bn (it is worth pointing out, however, that $1.9bn is just 38% of what HSBC calls its "underlying" pre-tax profit for the three months to September 30, so the penalties and forfeits are affordable and absorbable). What apparently weighed on Mr Breuer was that a criminal indictment of HSBC could have led it to lose its banking licence in New York. This could have destroyed HSBC's relatively small US retail banking business and - more importantly - severely impaired its ability to conduct business anywhere in the world: the reputational damage of being blacklisted in America would have been terrible and, without access to dollars from the New York Fed, HSBC's vast international wholesale operations would have been in trouble. As Mr Breuer put it: "The goal is not to bring HSBC down."