HBEU definition
Examples of HBEU in a sentence
In January 2001, HBEU approached HBUS with a proposal to clear U.S. dollar transactions for Bank Melli London (“Bank Melli”) through HBEU’s correspondent account with HBUS by utilizing Society for Worldwide Interbank Financial Telecommunication (“SWIFT”) MT 202 cover payments that would not reference Bank Melli.
HBUS proposed that HBEU address these compliance concerns by only processing Bank Melli payments as serial MT 103 messages.
Thus, by signing this Agreement, the Company agrees that the statute of limitations with respect to any such prosecution of HSBC Holdings pie or HBEU that is not time-barred on the date of the signing of this Agreement shall be tolled for the Term plus one year.
Any such prosecution relating to the conduct described in the attached Statement of Facts, Attachment A-1, or relating to conduct known to the Fraud Section prior to the date on which this Agreement was signed that is not time-barred by the applicable statute of limitations on the date of the signing of this Agreement may be commenced against the Company or HBEU, notwithstanding the expiration of the statute of limitations, between the signing of this Agreement and the expiration of the Term plus one year.
HSBC Group Compliance first provided dispensation to HBEU until October 31, 2006; the dispensation was ultimately extended until November 2007.
The HBEU senior payments official went on to seek guidance on two alternative responses to transactions stopped by HBEU’s interdiction software.
In a letter drafted in April 2001, an HBEU Business Development Manager explained to Bank Melli how to send payments to HBEU in a manner that would allow HBEU to process its payments successfully through HBUS.
In a September 23, 2005, email to an HSBC Group Money Laundering Control Officer and HSBC Group senior compliance official, the HBEU senior compliance official stated: The issues surrounding Iran have overshadowed other OFAC payments recently, however, I can advise that we have not so far physically returned any USD payments involving Sudan, Cuba or Burma [since the issuance of the GCL].
In December 2004, HBUS agreed to the proposal provided, inter alia, that all transactions would be fully transparent serial payments, and HBEU would agree not to alter any payment instructions.
The second alternative was to strictly apply the GCL and “return the payments unprocessed.” The HBEU senior payments official indicated his instinct was to use the second alternative and sought confirmation from HSBC Group Compliance before taking action.