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.  On March 12, 2019, the Department of Justice announced that Mizrahi-Tefahot Bank (Mizrahi-Tefahot) has entered into an Agreement on Deferred Criminal Prosecutions (DPA) in which it admits to helping U.S. taxpayers conceal income and assets and agrees to pay $195 million to the United States to avoid criminal prosecution. Both in the data protection authority registered by the BHBM and in the fundamental agreement signed by BHS, the DOJ found that at the beginning of its investigation, “the initial cooperation of the bank was insufficient”.  The Bank`s initial attempts at cooperation have been characterized, among other things, by insufficient internal investigation, the non-disclosure of relevant facts in a timely manner, and the provision of incomplete and, in some cases, inaccurate information and data to the DOJ. The DOJ also noted that hapoalim had not taken appropriate steps to receive emails, resulting in the removal of some relevant email boxes and backup tapes. Due to Hapoalim Bank`s lack of cooperation, the DOJ`s efforts to resolve its investigations in a timely manner have been hampered and its efforts to prosecute potentially guilty individuals have been thwarted. However, the DOJ acknowledged that during its investigation, the Bank intensified its efforts to cooperate fully.  In particular, the Bank replaced its external advisor, conducted an in-depth internal investigation, made regular presentations to the DOJ on a wide range of factual topics, provided relevant facts about the perpetrators of certain criminals, produced huge amounts of documents and facilitated interviews with persons involved in the DOJ. In the end, the DOJ assigned Hapoalim Bank a great deal of information related to the investigation.
 The amount is deducted from a fine of $118 million, as well as the return of profits from untaxed assets and taxes that were not paid as a result of illegal activities. The agreement provides for a two-year delay in the bank`s charge of conspiracy, so that the bank can comply with the terms of the agreement.