Stuart T. Gulliver
Thank you, Douglas. You all have seen the report from the United States Senate Permanent Subcommittee on Investigations, which has been extensively covered in the media and which has revealed our past shortcomings in relation to compliance with the U.S. regulations, including anti-money-laundering laws and the Office of Foreign Assets Control sanctions. We said in our annual results for 2011 and 2010 that we have been cooperating closely with U.S. authorities, but the subcommittee hearing will have been the first time most of you will have seen the detail. I very much regret HSBC's past failures, and I apologize for them. Our control should have been stronger and more effective. As you would expect, HSBC has a number of means to discipline people who fall short of our standards, including clawing back bonuses and dismissal, and a number of people have left the company.
But I also want to explain what we're doing to make HSBC more resilient and less likely to see a recurrence of these problems. When the new leadership team came in in 2011, we recognized that immediate action was required. First, we changed our organizational structure. In the past, we were organized along country lines for over 80 separate businesses. Our new structure, with 4 global businesses and 10 global functions plus HSBC technology and services, makes it easier to manage and control the firm. Basic global integration allows for a coordinated and consistent approach to compliance and to risk. We've made HSBC simpler through our Five Filter process. We have announced 36 disposals and closures since the start of 2011, exiting nonstrategic markets and selling businesses and non-core investments. These disposals make the firm more manageable, reduce risk and lets us concentrate on our strengths as an internationally connected bank.
We have also put a sharper focus on compliance and increased our spending on it to over USD 400 million. Under our new structure, Group Compliance has authority over all personnel all over the world. This puts us in a better position to detect and address compliance risk globally. We are adopting and importing adherence to a single regulatory standard globally that is determined by the highest standard we must apply anywhere, and this will typically be U.S. standards. This means, among other things, that we are maximizing information sharing for risk management purposes across HSBC to the extent permitted by privacy laws.