Sundar Pichai, CEO
Google Inc.
1600 Amphitheatre Pkwy
Mountain View, CA 94043
Re: Google Cloud AI-driven Anti-money-laundering Software Concerns.
I am an AML and Sanctions Consulting Expert hence a significant figure in the field of Anti-Money Laundering (AML) and a recognized whistleblower of the infamous HSBC Money Laundering Scandal. My prior experiences and meticulous investigations have yielded an invaluable wealth of knowledge in this sector, a knowledge I believe could be instrumental in shaping Google's strategic decisions concerning its Artificial Intelligence Anti-Money Laundering (AI AML) Cloud Services and associations. It is laudable that Google Cloud Services has taken pioneering steps in refining its AML AI by deploying machine learning for risk mitigation, moving away from the traditional rule-based approach. As noted by the Wall Street Journal, this innovative approach reduced HSBC's alerts by an impressive 60%. I am supportive of the technology itself; however, I am deeply concerned about its application in certain contexts. Let me draw your attention to the crux of my apprehension: HSBC Bank. While your AI is advanced, its efficiency is largely dependent on the user, who possesses the power to ignore its alerts. We must question if the reduced alerts have led HSBC to generate more Suspicious Activity Reports (SARs), critical for the US Government to acquire indispensable financial intelligence. In the past, I unearthed evidence that directly led to HSBC facing the heftiest fine ever imposed on a bank - a staggering $1.92 billion. The fine was a result of their illicit activities, including sponsorship of terrorism and drug cartels. My professional judgment and experience lead me to believe that HSBC has not significantly deviated from its earlier malpractices since that time.
HSBC's extensive correspondent banking division, coupled with its strategic geographical presence in Russia and the Middle East, allows it to move funds globally with ease. This puts American interests at risk, as they potentially aid entities such as Hezbollah. Disturbingly, I have witnessed firsthand manipulation of wire filter systems to facilitate funding to such organizations during my tenure as an Anti-Money Laundering compliance officer at HSBC. It is crucial to note that the lack of stronger punitive actions, including imprisonment of responsible executives or closure of the bank, was due to fears of an ensuing financial crisis, not a validation of HSBC's reformed behavior. It is distressing to envisage that your AI technology may be manipulated to continue this cycle of illicit transactions under the guise of due diligence, thereby jeopardizing American interests. To this end, I strongly caution Google about the potential ramifications of associating with HSBC Bank. The advanced AI technology you have developed is a double-edged sword - an instrument for progress in the right hands and a weapon for deceit in the wrong ones. Netflix's documentary series, "Dirty Money", specifically episode 4, "Cartel Bank", illuminates HSBC's manipulative practices. I suggest you peruse it for a deeper understanding of my concerns. I am also currently in talks with the FBI and prosecutors from the Southern District of NY to potentially reopen an investigation into HSBC's sanction violations. In light of these points, I strongly advise Google to reconsider its relationship with HSBC Bank to avoid inadvertently becoming entangled in the potential fallout of its dubious practices. There are many other Money Services Businesses (MSBs) that could greatly benefit from your AI AML technology, entities who would use these advancements for the betterment of the industry, and for truly mitigating the risks associated with money laundering.
Sincerely,
Everett A. Stern, M.B.A.
CEO / Intelligence Director, TR
United States of America