Finance committee  Certainly, there were external events that caused us to re-examine our overall control structure. It was well publicized that HSBC group had a large settlement with the U.S. authorities and U.K. authorities. That was preceded by a lengthy investigation in which we cooperated full

Finance committee  To my knowledge at least, HSBC does not attempt to really define what a tax haven would be; rather, we try to look at the various countries from a combination of risk factors. There may be corruption within the country, and we would look at the corruption perception index. It mig

Finance committee  First of all, HSBC in Canada is in a bit of a different position from my colleagues in the sense that we do not operate any wealth management or lending to businesses in any countries outside of Canada. I'd have to speak to HSBC Group. I'm not as knowledgeable about their practic

Finance committee  Yes, it would.

Finance committee  Mr. Chairman, I'll repeat those figures. You were correct. There were approximately 725 suspicious transaction reports in 2012, 96,000 large cash transactions, which is where a customer comes in and transacts more than $10,000 over a 24-hour period, and 600,000 electronic fund tr

Finance committee  I'm not aware of a particular instance where that has arisen.

Finance committee  Yes, Mr. Chairman, we do in fact employ whistle-blower controls within our organization, on a couple of levels. One is that the parent organization, HSBC Group, operates a compliance disclosure line, as we call it, which is in essence a whistle-blower line. That is staffed by p

Finance committee  Certainly, I think we find that the illicit actors, whether they be terrorist financiers or what you might call organized crime or other money launderers, are quite sophisticated. The tactics they use to avoid detection continually evolve and change, so detecting them always plac

Finance committee  There are two forms. One is obviously the sharing of best practices. There are a number of industry initiatives, whether it's through the CBA or some non-industry associations where we meet, learn, and discover best practices by others. There's obviously informal interaction.

Finance committee  The only thing I would add is that, like my colleagues, we have very much the same process. I would like to emphasize how you flag this sort of activity. I put it in two large categories: it's people and it's systems. We train our front-line staff, our relationship managers, and

Finance committee  In the case of HSBC, the short answer would also be yes. HSBC group has set a standard global requirement that sets the baseline, which is the minimum standard, and all countries and subsidiaries must observe it. It may be enhanced, if a particular country has higher standards, b

Finance committee  Actually, in the case of Canada, in certain respects it would set a component of the minimum threshold. If I were to give an example, in Canada we take two pieces of identification, whereas many other countries or many other laws will only require one piece of identification. So

Finance committee  Multilateral.

Finance committee  Mr. Chairman, the short answer is that high levels of standards and policies have always been in place. We discovered they were not observed as strictly as we had expected they would be. So in the new model for HSBC, we have implemented a compliance assurance function, which sits

Finance committee  Thank you, Mr. Chairman. Good morning. My name is Scott Bartos, and I am the senior vice-president and chief compliance officer for HSBC Bank Canada. I'm the senior executive responsible for the oversight of HSBC Canada's regulatory and AML compliance program. Just to give you