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Anti-money laundering

The proceeds of crimes such as fraud or drug trafficking need to be disguised and hidden. Similar techniques can be used by those involved in terrorist financing. This puts banks in the front line of the battle against the sort of money laundering which can undermine economic and social stability.

Our policies on AML are aligned with the requirements of the Financial Services Authority (FSA), our lead regulator, and with standards of international best practice such as the recommendations of the Financial Action Task Force (FATF). But our prevention programme is a dynamic one. As government initiatives against organised crime have become more effective and the controls used by banks have improved, money launderers have become more professional and increasingly sophisticated. We meet this challenge through three lines of defence:

  • Knowing Our Customers. We guard the gateway to our banking systems by verifying the identity of all new customers and undertaking further Customer Due Diligence (CDD) checks on a risk based approach. New procedures, developed in 2008 with the support of external consultants, have now been implemented across our entire business
  • Monitoring Transactions. Our CDD procedures ensure that we know who our customers are, but we also need to spot any suspicious occurrence among the millions of transactions we process through our business every day. We cannot meet this challenge without the support of increasingly sophisticated systems. The Norkom monitoring solution provides us with the flexibility needed to remain at the leading edge. By mid 2010, it will have been deployed across 20 countries in which we operate, covering more than 85 per cent of our customer base. We notify the authorities as soon as suspicious transactions are identified using a Suspicious Activity Reports or (SAR). This year we filed more than 10,000 SARs globally.
  • Training our Staff. Irrespective of the sophistication of our automated systems, the knowledge and vigilance of our own staff are still an essential part of our defences. Our training and awareness programmes make sure staff can meet their responsibilities.

Over the year we:

  • rolled out a global eLearning module in eight key languages to improve understanding by front line staff. More than 42,000 operational staff had completed the course by the end of the year
  • launched specialist training for more than 400 country level staff with specific AML related roles
  • developed, for launch in early 2010, specific training programmes for targeted staff in our Cash, Trade and SME businesses

Case Study: AML

Our Suspicious Activity Reports (SARs) can make a real difference to the efforts of governments in tackling the type of fraud which impacts society as a whole.

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Partnering with regulators

Case Studies: Partnering with Regulators

Mid year, we were again invited to join an Anti money laundering (AML) related task force team established by the Korean regulator, KoFIU.

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Report tools

Annual Report and Accounts 2009