In both 2003 and 2010, U.S. regulators ordered HSBC to strengthen its anti-money laundering practices.[140] In October 2010, the United States OCC issued a Cease and Desist Order requiring HSBC to strengthen multiple aspects of its Anti-Money Laundering (AML) program. The identified problems included a once massive backlog of over 17,000 alerts identifying suspicious activity, failure to file timely suspicious activity reports with U.S. law enforcement, failure to conduct any due diligence to assess risks to HSBC affiliates before opening correspondent accounts for them, a three-year failure by HBUS from mid-2006 to mid-2009 to conduct any AML of $15 billion in bulk cash transactions from those same HSBC affiliates, failure to monitor $60 trillion in annual wire transfers by customers in countries rated lower risk by HBUS, and inadequate and unqualified AML staffing, resources, and leadership.