FSA has described the actions it plans to take in relation to HSBC’s AML and US sanctions failings. FSA will take the actions as global lead regulator of HSBC. The actions, which are separate from, though complementary to, current US enforcement actions, including the Cease and Desist Order issued by the Federal Reserve Board and the Deferred Prosecution Agreement issued by the US Department of Justice on 11 December 2012, will require HSBC Holdings to:

  • set up a Board committee with a mandate to oversee matters relating to AML, sanctions, terrorist financing and proliferation financing;
  • review relevant group policies and procedures to ensure that all parts of the group are subject to standards equivalent to those required under UK requirements;
  • appoint a Group Money Laundering Reporting Officer (MLRO), who will be an FSA-approved person, with responsibility for ensuring that systems and controls are in place across the group, to ensure it complies with all relevant legal and regulatory requirements; and
  • employ an independent monitor to oversee the group’s compliance with UK AML, sanctions, terrorist financing and proliferation financing requirements and to provide independent reporting to the HSBC Board committee and regulators.

(Source: FSA Takes Action Against HSBC)