FINMA enforcement: serious breach of anti-money laundering obligations in two PEP relationships (funds from Lebanon)
FINMA opened proceedings in December 2021 and concluded in June 2024 that HSBC Private Bank (Suisse) SA breached its anti-money laundering obligations in two high-risk relationships with politically exposed persons; transactions between 2002 and 2015 totalled more than USD 300 million and moved from Lebanon to Switzerland and largely back. FINMA ordered a review of all high-risk and PEP relationships, a check of customer risk categorisation, an audit researcher on site, and a ban on new PEP relationships until the measures are implemented. FINMA stated the decision had not entered into force; no monetary penalty is stated.
The transactions in question were carried out between 2002 and 2015 and amounted to a total of more than USD 300 million.
Review of all current high-risk and PEP relationships from an AML perspective; check of risk categorisation of other customers; on-site monitoring by an audit researcher reporting to FINMA; detailed account of responsibilities within board and executive management.