Personal criminal liability works

Personal criminal liability works, like it or not


An old personal experience came to mind while reviewing the HSBC money laundering allegations. The bottom line is, if you want compliance, nothing works as well as personal criminal liability. Many years ago, I served as chief financial officer of what was then known as a Section 20 subsidiary of a US commercial bank – an investment banking business, in simpler language. One of the first things I learned was that I had personal criminal liability for proper reporting of the firm’s