Page 145 - Bank Case Studies
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Failure after failure at HSBC led to the bank being used as a

               conduit for "drug kingpins and rogue nations", a 300-page

               report compiled for a US Senate committee and had found.



               It was a bank, US prosecutors said, was guilty of 'blatant
               failure' to implement anti-money laundering controls and

               wilfully flouting U.S. sanctions.



               Assistant attorney general, Lanny Breuer, told a press
               conference in New York that Mexican drug traffickers

               deposited hundreds of thousands of dollars each day in

               HSBC accounts. At least $881m in drug trafficking money

               was laundered throughout the bank's accounts and

               facilitated hundreds of millions more in transactions with

               sanctioned countries." (1, 3)


                                                        The penalty included a deferred

                                                        prosecution agreement with the

                                                        DOJ of five years under which the

                                                        bank would install an

                                                        independent monitor to assess

                                                        reformed internal controls.

                                                        Moreover, the bank's top

               executives were to defer part of their bonuses for the whole

               of the five-year period, while bonuses have been clawed

               back from a number of former and current executives,
               including those in the US directly involved at the time.


                              “Gulliver stressed that the bank had co-operated

                              with the US authorities. "Over the last two years,

                              under new senior leadership, we have been taking

                              concrete steps to put right what went wrong and
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