Tackling financial crime


The scale and impact of financial crime is enormous. The International Monetary Fund estimates that money laundering – disguising criminal proceeds as legitimate funds – accounts for between two and five per cent of the world’s economic output, or over $1 trillion per year.

Financial crime affects customers and their communities, often affecting vulnerable, lower-income groups and thus fuelling poverty and inequality. It is prevalent in all markets, but in developing countries it is particularly damaging because it impedes economic development. As for any bank, financial crime exposes us to reputational risk as well as financial loss.

To mitigate the risks, we concentrate on three key areas:

  • Prevention of money laundering and terrorist financing
  • Compliance with government sanctions against criminal suspects
  • Minimising the risk of fraud, corruption and insider trading

Managing risks

We apply our resources, systems and processes to the highest risk areas. In other words, our aim is to concentrate our efforts where they have the greatest impact in minimising the damage financial crime causes.

Once we identify relevant risks, our specialist teams design policies and controls to manage them. The specialist areas cover fraud, anti-money laundering and terrorist financing, bribery and corruption, financial sanctions, and market abuse. These controls are then implemented by the businesses. The internal policies that guide our work are available here.


  • Norkom deployed to five new markets, bringing the total to 13 countries
  • Group Code of Conduct refreshed to include anti-corruption training
  • More than 12,000 staff provided with access to the Norkom Account Opening Check system to screen all new accounts for potential criminals and international sanctions targets
  • Customer Due Diligence procedures and systems enhanced


  • Launched a refreshed Group Code of Conduct which includes anti-corruption training
  • 12,000staff able to screen new accounts
  • 640 per centincrease in internet fraud incidents investigated