The DOJ had previously entered into legal agreements with Leumi Group Bank (see USA). Dep`t of Justice, press release, Bank Leumi admits to helping U.S. taxpayers transfer assets to offshore bank accounts (December 22, 2014), available here: www.justice.gov/opa/pr/bank-leumi-admits-assisting-us-taxpayers-hiding-assets-offshore-bank-accounts) and Mizrahi-Tefahot Bank Ltd. (see U.S. Dep`t of Justice, Mizrahi-Tefahot Bank Ltd – Deferred Prosecution Agreement (March 12, 2019), available here: www.justice.gov/opa/press-release/file/1176116/download). Hapoalim said the U.S. probe examined the accounts held by some of the suspects with the bank.  U.S. Dep`t of Justice, Press release, Bank Hapoalim agrees to pay more than $30 million for its role in the FIFA money laundering conspiracy (April 30, 2020), www.justice.gov/opa/pr/bank-hapoalim-agrees-pay-more-30-million-its-role-fifa-money-laundering-conspiracy.
The SEC order indicates that Leumi Bank made $3.3727 million in profits from its cross-border operations in the United States. In December 2014, Leumi Bank cancelled $3.307 million of these gains in a deferred law enforcement agreement with the U.S. Department of Justice. Leumi Bank must deduct the remaining $65,700 in its settlement with the SEC, plus $8,713.20 in interest and a penalty of $1,517,715. Hapoalim also said he expects to pay $30 million in a non-prosecution deal he plans in the fourth quarter to resolve a U.S. investigation into alleged corruption involving FIFA officials. The DOJ`s decision to join the AFN was based in particular on (1) Hapoalim Bank`s assertion that it would leave private banking activities outside Israel and “take all necessary measures to close BHS and issue its banking licence” (2), and (2) Hapoalim Bank`s “exemplary cooperation” with the DOJ investigation.  Although Hapoalim Bank did not receive a voluntary disclosure credit, because it did not voluntarily and in a timely manner disclose the conflicting conduct, it was fully recognized for its collaboration, which included “conducting a full internal investigation,” “de facto presentations” on a wide range of topics, “checking more than 250,000 documents and hundreds of audio recordings,” “creating translations of important documents and transcripts of audio files” and “making available to collaborators for interviews.”  The bank stated in an administrative notification that it would increase its provision for tax control to $259 million in the fourth quarter, in addition to the $611 million it had already set aside. On the same day, The Bank also agreed to pay additional fines of more than $30 million for a three-year non-prosecution agreement (“NPA”) with the DOJ`s Department of Money Laundering and Asset Recovery and the U.S.
Attorney`s Office for the Eastern District of New York, to clarify an investigation into the bank`s involvement in a bribery and bribery conspiracy.  “The registration rules for dealers and investment advisors provide central protection for investors,” said Scott Friestad, associate director of the SEC`s Enforcement Division. “Leumi Bank`s efforts to comply with these laws have lasted for years, during this period the bank has continued to benefit from its illegal cross-border operations.” After the department`s investigation against UBS and other Swiss banks to help U.S. taxpayers evade tax was made public, Leumi Group Bank opened and managed accounts for U.S. taxpayers who left UBS and other Swiss banks as a result of the investigation, in order to prevent the U.S. government from continuing to investigate. “Recently, the banking group and each of the DOJ regulatory teams and the banks conducting the investigations negotiated at length the terms of the decisions that had been approved by the United States.