HSBC Swiss bank accounts-
AML compliance and money
Mohammed Ahmad Naheem
Seven Foundation, Zurich, Switzerland
Purpose – This paper aims to provide an analysis of the HSBC Swiss bank accounts scandal, from the
perspective of anti-money laundering (AML) compliance, and considers the future AML implications
for the banking sector and HSBC. It reviews the use of a whistleblower to highlight AML irregularities
rather than ofcial reporting through the current AML compliance system.
Design/methodology/approach – The paper uses secondary data to offer a viewpoint on the HSBC
issues from a money laundering and nancial crime perspective. The paper extracts key statements
from staff at HSBC and regulators and examines how AML risk assessment was undertaken at this time
and what changes need to occur in the future. It considers the implications of the current theoretical
context for AML from an agency theory perspective.
Findings – The main ndings are that AML compliance needs to be embedded into a proactive
corporate social responsibility approach rather than relying solely on regulation to improve detection
and reporting of money laundering activity.
Research limitations/implications – The research topic is new, and therefore, analysis papers and
other academic writing on this topic are limited. Future research could consider the outcomes of the
Swiss bank’s attempts to prosecute the whistleblower and whether this would have implications for
future internal reporting and whistleblowing approaches to support AML compliance.
Practical implications – The implications from the research are the recommendations to the
banking sector on addressing AML deciencies especially within the context of an evolving level of
criminal sophistication towards money laundering.
Social implications – The paper supports the argument for integrating social corporate
responsibility and AML compliance to produce a whole bank response to nancial crime. This is in
contrast to the current systems, which seem to be prevalent within the nancial services, of prot and
business being seen as separate rather than integral to regulation and control.
Originality/value – The originality of this paper is the current example of the HSBC Swiss case and the
focus specically on AML compliance rather than tax evasion, which has been the media angle on the issue.
Keywords Compliance, Corporate social responsibility, Anti-money laundering, HSBC,
Swiss banking, Trade-based money laundering
Paper type Viewpoint
The author acknowledges being the recipient of a research grant awarded by Princess
Alae as part
of Seven Foundation’s “2020 Banking Vision – building banks of the future” and he thanks her for
the continued support and motivation both to himself and other students who benet through her
generosity (www.sevenfoundation.ch). The author also thanks Professor Muhammad Jum‘ah (a
leading economist of this era based in Damascus) who has continued to provide valuable input
both through his teaching of the science of economics and for his continued guidance.
The current issue and full text archive of this journal is available on Emerald Insight at:
Journalof Financial Regulation
Vol.23 No. 3, 2015
©Emerald Group Publishing Limited