As it ramps up a massive marketing campaign in Asia and the Middle East, (I am being besieged with emails touting the bank's financial solvency and availability as a valued financial resource) I note that, in all the civil litigation brought by its unhappy customers, the bank's primary defense is that they are all money launderers, tax evaders and yes, terrorist financiers. How on earth can a bank advertise SPOTLESS COMPLIANCE, when at the same time claiming its existing customers are financial criminals who also provide material support to sanctioned terrorist organizations?
Every new Hamilton client, all of whom must deposit a minimum of one million dollars (USD$1,000,000), is required to execute a sworn affidavit on Source of Funds, and provide sufficient documents to prove it. How can the bank later claim those clients are all money launderers, and the subject of pending criminal investigation in the United States (which they conveniently have not proven) and all bad actors, whom they therefore cannot disburse their own money to? This means either their compliance program is complete garbage, meaning ineffective, or they took deposits, fully intending to illegally retain them. Either way, this is not how legitimate banks are required to operate. Let potential future clients govern themselves accordingly.

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