HSBC Bangladesh

01The challenge

I joined HSBC Bangladesh during a period of heightened scrutiny by the independent Monitor appointed under HSBC’s agreement with the US Department of Justice. The Bangladesh business needed to reduce financial crime exposure, strengthen controls and demonstrate credible progress to the Monitor.

02My role

I led the local internal audit team and worked with senior management to identify control weaknesses and support a stronger culture of compliance with HSBC’s global anti-money laundering (AML) and financial crime compliance (FCC) requirements. This included assessing controls intended to ring-fence financial crime risks.

03What we delivered

We conducted FCC audits across HSBC Bangladesh’s business segments and processes, identifying numerous control gaps and recommending corrective action. Our work gave management independent assurance and a clearer basis for prioritising remediation.

04The outcome

The Bangladesh team strengthened its controls and successfully navigated the Monitor’s review. My contribution formed part of HSBC’s wider global remediation effort. At Group level, the AML Deferred Prosecution Agreement expired in December 2017, and the deferred charges were subsequently dismissed.

Group-level outcome: HSBC Annual Report and Accounts 2017 ↗

05My professional reflection

My experience highlighted a difference in risk awareness: credit risk was well understood and embedded in banking decisions, while financial crime risk awareness and AML practices were less consistently established.

Customer onboarding illustrated this challenge. Missing or inaccurate information could weaken customer due diligence, while unreliable or falsified supporting documents made independent verification particularly important.

These challenges reinforced the need for a questioning mindset, reliable verification and management ownership of financial crime controls throughout the customer relationship.

06What this experience brings to clients

I help boards, management and audit teams assess financial crime controls, identify underlying weaknesses and strengthen compliance culture. The aim is to make AML requirements part of everyday business decisions, supported by effective controls and independent assurance.