Tuesday, November 29, 2016


The recent news, to the effect that a report, by the court-appointed Monitor of HSBCs AML/CFT reform process, was leaked to the press, and that the report allegedly noted that there were more than a dozen HSBC accounts that were linked to Syrian terrorist organizations, was said to have immediately provoked a "furious" response from senior bank management, is extremely distrubing. Don't those chaps get it yet: HSBCs AML/CFT program was adjudged an utter failure, and yet you are angry at a whistleblower ?

When the corporate culture of a bank, with decades of AML failures on a global scale, refuses to reform, it is time for a new strategy. Inasmuch as the bank cannot clean up its compliance regime to the point where it attains a satisfactory level, dismantle the bank, and sell off the national components to banks that have a history of successful AML/CFT programs. Is this too radical for you to contemplate ?

The alternative is dreary; the bank, time & time again gets rapped for systemic compliance failures, but there is no true reform, no matter how punitive the sanctions visited upon the bank are. The greed (profit) factor is simply too strong in the bank's corporate culture to be tamed, with the usual dire consequences for effective/compliance.

If you have a viable solution for HSBCs compliance report card, which has earned an "F" for as long as I can remember, I would love to hear it. Otherwise, think about doing the unthinkable: break the bank up, so that narcotics profits, bribes & kickbacks, and the proceeds of corruption no longer have a welcome destination for placement of illicit funds.

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