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HSBC: Lapse in AML Program

Posted on 5/3/12 at 11:13 pm
Posted by MStant1
Houston, TX
Member since Sep 2010
4527 posts
Posted on 5/3/12 at 11:13 pm
LINK


Hope none of you poor saps work for HSBC.

Based on this report I will be a very busy man on the remediation that is sure to follow. I may never see the sun again. Job security I guess.


quote:

In April 2003, the Federal Reserve Bank of New York and New York state bank regulators cracked the whip on HSBC Bank USA, ordering it to do a better job of policing itself for suspicious money flows. Staff in the bank's anti-money laundering division, according to a person who worked there at the time, flew into a "panic."


quote:

The U.S. unit of London-based HSBC Holdings Plc quickly rallied. It hired a tough federal prosecutor to oversee anti-money laundering efforts. It installed monitoring systems for operations that had grown unwieldy during the bank's U.S. expansion. The aim, as HSBC said in an agreement with regulators at the time, was to "ensure that the bank fully addresses all deficiencies in the bank's anti-money laundering policies and procedures."

Nearly a decade later, the effort has failed to satisfy law-enforcement officials.


quote:

The extent of that failure is laid out in confidential documents reviewed by Reuters that originate from investigations of HSBC's U.S. operations by two U.S. Attorneys' offices.

These documents allege that from 2005, the bank violated the Bank Secrecy Act and other anti-money laundering laws on a massive scale. HSBC did so, they say, by not adequately reviewing hundreds of billions of dollars in transactions for any that might have links to drug trafficking, terrorist financing and other criminal activity.


quote:

In some of the documents, prosecutors allege that HSBC intentionally flouted the law. The bank created an operation that was a "systemically flawed sham paper-product designed solely to make it appear that the Bank has complied" with the Bank Secrecy Act and is able to detect money laundering, wrote William J. Ihlenfeld II, U.S. Attorney for the Northern District of West Virginia, in a draft of a 2010 letter addressed to Justice Department officials.

In that letter, Ihlenfeld compared HSBC unfavorably to Riggs Bank. In 2004 and 2005, that scandal-plagued Washington bank was fined a total of $41 million after it was found to have violated anti-money laundering laws, and it was acquired by PNC Financial Services.

"HSBC is to Riggs, as a nuclear waste dump is to a municipal land fill," Ihlenfeld wrote.





The article goes on, but basically it describes the overall incompetence in HSBC's compliance dept. This is why consultants have jobs.
This post was edited on 5/3/12 at 11:14 pm
Posted by kfizzle85
Member since Dec 2005
22022 posts
Posted on 5/3/12 at 11:59 pm to
Curious to see how this plays out given HSBC generally being a stellar global bank by global bank standards and their full exit from the US a few years ago. Between this and their epic fail acquisition of Household a few years ago, they must really hate the USA. All things being equal I bet its a generic slap on the wrist fine of a few hundred million at best. Nothing to scoff at, unless your product is money.
Posted by MStant1
Houston, TX
Member since Sep 2010
4527 posts
Posted on 5/4/12 at 9:37 am to
quote:

Curious to see how this plays out given HSBC generally being a stellar global bank by global bank standards and their full exit from the US a few years ago. Between this and their epic fail acquisition of Household a few years ago, they must really hate the USA. All things being equal I bet its a generic slap on the wrist fine of a few hundred million at best. Nothing to scoff at, unless your product is money.



HSBC actually has had the reputation for awhile of being less than stellar in terms of compliance. They've been getting fined left and right for the past two years.

The thing to keep in mind a 100 million dollar fine isn't the end of the story. You also have to take into consideration the several million it will take to remediate these issues. Already they are spending several million dollars a year on consultants to fix issues that came out in 2010 which also doesn't include any money spent on updating systems etc. To remediate this current issue will probably be another 20 million+ dollar project. That's a lot of money for a compliance department to be bleeding when all accumulated together.

Also I don't think this is a US specific issue. The EU and UK have very similar AML compliance regulations as the US.
Posted by ZereauxSum
Lot 23E
Member since Nov 2008
10176 posts
Posted on 5/4/12 at 10:10 am to
quote:

The bank created an operation that was a "systemically flawed sham paper-product designed solely to make it appear that the Bank has complied" with the Bank Secrecy Act


Why go through the effort to "fake" compliance with the law?

It's not like the Secrecy Act is hard or costly to comply with. It's basically reporting of large cash transactions and suspicious looking transactions. Everyone from the tellers on up knows what shady account activity looks like.
Posted by kfizzle85
Member since Dec 2005
22022 posts
Posted on 5/4/12 at 10:12 am to
I was just referring to their financial situation, I know absolutely nothing about their compliance standards, although its interesting to note just from the sake of a management standpoint.
Posted by MStant1
Houston, TX
Member since Sep 2010
4527 posts
Posted on 5/4/12 at 10:15 am to
quote:

It's not like the Secrecy Act is hard or costly to comply with. It's basically reporting of large cash transactions and suspicious looking transactions. Everyone from the tellers on up knows what shady account activity looks like.



LULZ!

This statement would have been true prior to the Patriot Act.

An AML compliance program for a bank like HSBC is SO much more than what you described. An AML program is also much larger than just cash transactions. I don't know where you have been, but banks have been spending a lot of money in order to be AML compliant since the Patriot Act was passed.
This post was edited on 5/4/12 at 10:18 am
Posted by ZereauxSum
Lot 23E
Member since Nov 2008
10176 posts
Posted on 5/4/12 at 10:26 am to
Ah, forgot about the Patriot Act. Yeah, I suppose things might have changed since then

Before 9/11, it really was a non issue. I actually work at a bank, but I do nothing with deposit accounts or active loans.
Posted by MStant1
Houston, TX
Member since Sep 2010
4527 posts
Posted on 5/4/12 at 10:33 am to
quote:

Ah, forgot about the Patriot Act. Yeah, I suppose things might have changed since then

Before 9/11, it really was a non issue. I actually work at a bank, but I do nothing with deposit accounts or active loans.


Yeah, prior to the Patriot AML was a very minor part of compliance. Today every major bank has an entire separate division of Compliance specifically for AML. The past 3 years the regulators have really been harping on AML too. Not so cheap fines that require not so cheap fixes. The Patriot Act gave the BSA very sharp teeth.
Posted by tigermannola83
New Orleans
Member since Sep 2010
97 posts
Posted on 5/6/12 at 10:11 pm to
Aml Compliance is quite costly and not as "easy" as you painted it there... I work in AML for a top 5 bank and the bar banks are being held to is ever changing. It is much like hitting a moving target.. This does not sound good for HSBC.
Posted by Gujam8
Member since Jun 2010
2361 posts
Posted on 5/6/12 at 10:25 pm to
quote:

Aml Compliance is quite costly and not as "easy" as you painted it there... I work in AML for a top 5 bank and the bar banks are being held to is ever changing. It is much like hitting a moving target.. This does not sound good for HSBC.



I have a friend with an AML certificate/certified associate (no banking experience otherwise) and he's been looking for an entry-level job in the AML dept, but hasn't been successful in getting one. Any advice on how he can get a start or just the industry itself? TIA
Posted by MStant1
Houston, TX
Member since Sep 2010
4527 posts
Posted on 5/7/12 at 8:14 am to
Tell your friend to look into consulting that's what I do.

If he doesn't want to do consulting, then picking up a jr analyst role shouldn't be too hard. It's a really easy job at the analyst level.

Some of it depends on where your friend lives. AML positions are much more plentiful and pay significantly more in cities like NYC and Charlotte. If your friend lives in Louisiana, then he may be looking for awhile. I know Capital One hires some for AML in New Orleans.
Posted by Gujam8
Member since Jun 2010
2361 posts
Posted on 5/7/12 at 5:42 pm to
quote:

Tell your friend to look into consulting that's what I do.

If he doesn't want to do consulting, then picking up a jr analyst role shouldn't be too hard. It's a really easy job at the analyst level.

Some of it depends on where your friend lives. AML positions are much more plentiful and pay significantly more in cities like NYC and Charlotte. If your friend lives in Louisiana, then he may be looking for awhile. I know Capital One hires some for AML in New Orleans.


Thanks MS. He's in Florida right now and tried to apply at Citi and a few other local banks and didn't get any response. He feels his lack of banking experience is hurting him, even though he took a course to be AML certified and tried to make his resume look good.

How does he go about with the consulting gig? AML consulting? Can you get a jr. analyst position without any AML work exp? He's willing to move to any other state and just needs a start (not too concerned with $ salary either)

btw, sorry for hijacking this thread..since y'all were talking about AML, I figured I'd ask here.
Posted by MStant1
Houston, TX
Member since Sep 2010
4527 posts
Posted on 5/8/12 at 9:14 am to
quote:

Thanks MS. He's in Florida right now and tried to apply at Citi and a few other local banks and didn't get any response. He feels his lack of banking experience is hurting him, even though he took a course to be AML certified and tried to make his resume look good.

How does he go about with the consulting gig? AML consulting? Can you get a jr. analyst position without any AML work exp? He's willing to move to any other state and just needs a start (not too concerned with $ salary either)

btw, sorry for hijacking this thread..since y'all were talking about AML, I figured I'd ask here.


Where in Florida? Miami has a pretty decent job market for AML jobs.

What is your friend's work background and degree in? Does he have any financial services work experience at all? It's going to be tough, though, not impossible to break into AML without any banking experience.

I got into consulting straight out of school in the consulting/advisory practice of one of the Big 4 accounting firms. Though if your friend doesn't have any financial services experience his chances of being hired at a Big 4 are slim to none.

Tell your friend to just start job searching contractor positions for AML. A lot of the big banks are hiring temp analysts to clear back logs of work. The hiring standards for these temps are often a little lower so he may be able to break in as an independent contractor. He may have to re-locate temporarily, but it may be the easiest way to break in.
Posted by Gujam8
Member since Jun 2010
2361 posts
Posted on 5/8/12 at 1:23 pm to
quote:

Where in Florida? Miami has a pretty decent job market for AML jobs.



He's in Orlando right now...does have an undergrad in finance, but no financial experience per se. (mostly in marketing) I don't think he's really looking for Big 4 right now..just any bank that gets him a start and experience in AML.

Thanks for the info..I'll let him know.
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