Skip to main content

Our approach and progress

2010 goals Status Achievements
Provide additional training to frontline staff in areas at higher risk of money laundering Completed 1,000 anti-money laundering (AML) specialists certified to our internal standards. 2,000 staff trained within trade operations. Face-to-face training in Africa, Asia and the Middle East, including 550 staff in our shared service areas processing transactions in Chennai, Kuala Lumpur and Tianjin
Implement seven additional detection scenarios to identify more patterns of suspicious activity Completed These were successfully tested and implemented through our Norkom AML monitoring system during 2010
Further enhance sanctions-screening systems to improve name identification and expand coverage Completed Enhanced matching logic was delivered in three of our major centres in 2010, with further improvements planned for Q1 2011
Extend Norkom AML monitoring system coverage Ongoing The Norkom AML monitoring system was rolled out in Jersey and Taiwan
Implement our enhanced Speaking Up programme Ongoing The enhanced Speaking Up programme was rolled out across the Group during 2010, providing channels for staff to report suspected or actual breaches of law, regulation, internal policy and procedures. The programme is available in 14 different languages, 24 hours a day
Strengthen controls for anti-bribery in higher risk business segments Ongoing The 2010 UK Bribery Act has led to a major programme of work to ensure that we are compliant with its requirements, including a risk assessment in 20 of our major markets and cross-bank augmentation of controls

2011 priorities:

  • Identify smarter ways of authenticating identity (eg, biometrics)
  • Implement a cross-bank financial crime case management system
  • Provide a more comprehensive investigations framework, covering serious fraud, Speaking Up cases, market manipulation and regulatory enquiries
  • Further enhance detection capabilities against branch banking, internal and application frauds
  • Roll out new anti-bribery procedures and training to comply with the UK Bribery Act, expected to come into force in the first half of 2011
  • Deliver the revised AML certification programme, launched in late 2010, to ensure that employees engaged in customer on-boarding and advisory roles are given more advanced training on AML awareness and procedures
  • Launch a product-specific eLearning programme for staff in Cash Operations, further strengthening our AML and Counter-Terrorist Financing (CTF) defences in this higher risk business area
Annual Report and Accounts 2010