HSBC’s chief legal officer has figured out how to ferret out “the truly bad actors:” Part of it involves the bank actually looking for them, but the much bigger part comes with a bill to taxpayers.
“Having a first-rate compliance program is necessary to protect the institution and comply with the law, but not sufficient to identify which are the truly bad actors,” HSBC’s chief legal officer Stuart Levey said at a London conference, according to prepared remarks.
The public and private sectors rely largely on “separate bodies of information” to combat financial crime, which leads to both groups “fighting this battle with one arm tied behind our backs,” he said….
For instance, the private sector reports potentially nefarious conduct to the government through methods like “suspicious activity reports,” but has no understanding of ”the illicit conduct government is most concerned about and its assessment of who may be engaged in that conduct. The reporting would be enhanced if there were a greater understanding of the government’s concerns.”
HSBC’s Top Lawyer on What Banks Need to Spot “Truly Bad Actors” [WSJ Risk & Compliance Journal blog]