BankThink

Bankers must remain vigilant about their sources of liquidity

A banking sector liquidity crisis cannot be allowed to create an opportunity for money laundering, writes Mikhail Karataev.

The causes of financial crises aren't repeated in practice, but their impact on banks is often identical. One unexpected outcome of the 2008 crisis was the bailout of banks with criminal funds. That's why it's important to avoid old mistakes in a new wrapper in 2024.

The banking system is going through a difficult period, with the Federal Reserve's benchmark interest rate at its highest level in 22 years. High rates make lending difficult and exacerbate bank liquidity problems, so three of the four largest bank failures in U.S. history occurred in 2023, and their total assets exceeded the sum of the 25 financial institutions that failed in the 2008 crisis. Other crises in July (Heartland Tri-State Bank, Farmington State Bank) and November (Citizens Bank, of Sac City, Iowa) allow us to talk about systemic risks.

According to A.M. Costa, the head of the United Nations Office on Drugs and Crime, "drugs money worth billions of dollars kept the financial system afloat at the height of the global crisis 2008." Liquidity was the banking system's main problem in 2008 and, in many instances, the money from drugs was the only liquid investment capital. Liquidity problems are again at the top of the agenda for banks in 2024 and it's important to minimize the risks of criminal influence.

In a financial crisis, banks may turn to the Fed for additional liquidity. U.S. banks borrowed a record $165 billion from the Fed on March 16, 2023 (50% more than the maximum of the 2008 crisis) and repeated the 2008 record of $110.2 billion just a week later. The correct decision for banks to request liquidity from the Fed is a signal to the regulator about the systemic errors of management. President Joe Biden warned that management of bankrupt banks will not only be fired, but also involved in investigations at the federal level. This prospect doesn't suit bank managers, who will look for other solutions.

An alternative route is to find liquidity yourself to maintain the reputation of a successful manager. Banks have had an unusually difficult year in 2023 with the biggest deposit drop in U.S. history ($872 billion). According to Moody's, U.S. banks could be grappling with at least $650 billion of unrealized losses in their securities portfolios. In such a critical situation, managers of banks may prefer to receive money from unknown beneficiaries or suspicious sources instead of bankruptcy.

International criminal organizations have the financial resources and need banks' assistance in money laundering. The annual volume of the world drug market could exceed $1 trillion, which is only 30% of the total income of transnational crime. It's also necessary to take into account the huge criminal resources of the crypto market, which can exceed $70 billion. An important feature of the criminal crypto market is a large concentration of resources, which allows their owners to offer substantial liquidity to banks in trouble. For example, the U.S. Department of Justice charged Ho Wan Kwok with orchestrating a cryptocurrency-related fraud worth over $1 billion. In addition, the U.S. Government seized approximately $634 million from 21 different bank accounts.

Payments fraud is the most expensive kind, at $450B; anti-financial-crime execs are the most worried about real-time payments, a survey from Nasdaq and Oliver Wyman found.

January 16
Nasdaq signage

Summarizing the experience of previous financial crises makes it possible to predict the immediate prospects for U.S. banks.

The easiest and cheapest way is to reduce compliance procedures. The Bitzlato crypto exchange could exist in 2018-2022 only because it attracted customers with lax know-your-customer procedures and the possibility of criminal money laundering. An internal spreadsheet saved in Bitzlato's shared management folder encapsulated the company's view of itself: "Positives: No KYC. … Negatives: Dirty money." Large banks use similar methods. A striking example was the situation with BNP Paribas, which admitted that from 2004 through 2012, it knowingly and willfully moved over $8.8 billion through the U.S. financial system on behalf of Sudanese, Iranian and Cuban sanctioned entities.

Banks also often resort to cost minimization. U.S. banks cut 20,000 positions in 2023. Compliance doesn't bring profit to banks and doesn't make money, so this department may be one of the first to face budget cuts. An unreasonable reduction in compliance staff will increase the burden on employees, which in the current "perfect sanctions storm" will inevitably lead to errors and turn into a violation of the law. The losses from regulatory fines and reputational damage can be much larger than the savings from downsizing the compliance department.

The position of the government is the third factor that has a direct impact on banks. Joe Biden announced the general line of federal policy in banking control, saying, "I am firmly committed to holding those responsible for this mess fully accountable and to continuing our efforts to strengthen oversight and regulation of larger banks so that we are not in this position again." It can be concluded that the government is vehemently opposed to the use of high-risk business practices in finance, even in the face of the growing crisis in the banking sector.

Thus, the criminal economy has liquidity, which is currently missing in the modern banking sector. Bankers must be vigilant about their clients' sources of funds. Client rights shouldn't outweigh U.S. goals and banking stability shouldn't promote money laundering. That's why it will be necessary to pay special attention to compliance issues and sources of liquidity for banks as the financial crisis grows.

Modern crises will differ in both depth and scope, affecting the whole world. "A lost decade could be in the making for the global economy," said Indermit Gill, the World Bank's chief economist. Despite the growth of economic crime and significant Fed control banks are focused on reducing overall costs and current liquidity. Dealing with the new economic reality is possible only for banks that will become more efficient with fewer resources. That's why banks need highly qualified employees as a modern compliance risk-based approach policy. As a result, compliance becomes an independent competitive advantage.

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Regulation and compliance Money laundering Financial crimes
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