- Understaffing its anti-money laundering compliance division, including staffing the division with incompetent personnel;
- Failing to review internal anti-money laundering alerts and failing to generate SARs on transactions that the bank’s internal monitoring systems picked up; and
- Management intentionally deciding to not review alerts of suspicious activity and altering risk ratings on clients to avoid the detection of suspect transactions by the firm’s internal monitoring systems.
The Reuter report highlights the need for adequate compliance policies in this highly regulated area. Perhaps more importantly, however, the investigations by regulators into HSBC’s conduct underscore the importance of implementing sufficient procedures and testing mechanisms to ensure anti-money laundering procedures are actually followed.For additional information about anti-money laundering laws and regulation, or any other compliance concern please contact JLG at (619)298-2880.