Anti-Money Laundering Policy Statement. Expanded. Elements of section shown. Hide section.
HSBC (all wholly owned or controlled HSBC Group of companies) is committed to implementing minimum control standards across all jurisdictions for which it operates.
HSBC established a Global Anti-Money Laundering Policy (“AML Policy”) for this purpose. The objective of the AML Policy is to identify and appropriately manage money laundering risks identified by HSBC. This is achieved by establishing and implementing appropriate processes, systems and controls to protect HSBC, its customers, shareholders, employees, and the communities it serves from money laundering. The AML Policy sets out the minimum control standards to all HSBC group entities and employees, requiring them to conduct business in accordance with applicable AML laws, rules, and regulations.
The AML Policy is informed by applicable laws, regulations, regulatory guidance and best practice from the United Kingdom, European Union, Hong Kong and the United States of America. In cases where material differences exist between the rules and regulations of these authorities or countries, the AML Policy adopts the highest standard; while acknowledging the primacy of local law.
The Policy includes:
- The appointment of a Global and Country Money Laundering Reporting Officer (“MLRO”) or alternative position as required by local regulation
- Minimum Customer Due Diligence (“CDD”) requirements, incorporating Customer Identification and Verification (“ID&V”) and Know Your Customer (“KYC”) principles
- Conducting enhanced due diligence (“EDD”) on customers assessed as higher risk; such as Politically Exposed Persons (“PEPs”) in senior positions, their relatives and close associates
- Establishing processes and systems designed to monitor customer transactions for the purpose of identifying suspicious activity
- The investigation and subsequent reporting of suspicious activity to the appropriate regulatory and/or law enforcement bodies
- Mandated regular AML training of employees and contractors
- The prohibition of the following products, services and customer types:
- Anonymous accounts or numbered accounts or customers seeking to maintain an account in an obviously fictitious name
- Shell banks, i.e. banks with no physical presence or staff
- Hold Mail, i.e. where the customer has instructed all documentation related to the account are to be held on their behalf until collection
- Payable-through-accounts, i.e. HSBC does not allow domestic or foreign bank customers to provide payable-through-accounts to their customers on their HSBC accounts
- Mandated regular independent testing by second line assurance function and third line audit function; and
- Any relevant additional local requirements
HSBC is a member of the Wolfsberg Group, an association of thirteen global banks that aims to develop financial services industry standards for KYC, AML and Counter Terrorist Financing.