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Paul Moore is the former Head of Group Regulatory Risk at HBOS and one of the most controversial figures to emerge from the era of the ‘credit crunch’.
In 2007, HBOS was one of the UK’s largest banks with assets of over £660 billion, over 74,000 staff and profits before tax of £5.4 billion. When the banking crisis hit, HBOS had to be rescued through a forced acquisition by Lloyds Banking group supported by government capital and liquidity support.
Dubbed in the press as “The HBOS Whistleblower”, Paul Moore was the only senior risk and compliance executive in UK banking sector to speak out publicly in the aftermath of the financial crisis about what he saw from the inside of a bank.
His influential evidence to the UK Parliamentary Treasury Select Committee in February 2008 was widely publicised in the media worldwide and led directly to the resignation of Sir James Crosby who was then the Deputy Chairman of the Financial Services Authority. Paul claimed that Sir James Crosby, when he was the CEO of HBOS, dismissed him as Head of Group Regulatory Risk for reporting that the sales culture had become markedly out of balance with risk and compliance systems and that the Board should reconsider its continued strategy for sale growth if it wished to avoid risks to customers and colleagues.
He maintained that failures in governance, risk management and compliance were at the heart of the banking crisis. In particular, he pointed to strategies with an excessive focus on sales, cultures that facilitated “group think” and resisted challenge and the lack of rigorous oversight and challenge by internal control functions, the non-executive and the FSA.
In his evidence to the Treasury Select Committee he said – “You can have the best governance processes in the world but if they are carried out in a culture of greed, unethical behaviour and an indisposition to challenge, they will always fail”.
Prior to HBOS, Paul was a Partner at KPMG in London advising banks, insurance companies and asset managers on risk, governance, regulatory compliance and ethics. Paul is a UK lawyer and has over 25 years of experience in the financial sector in these areas including working in industry for 15 years as a “coal-face” practitioner at Allied Dunbar, American Express Financial Advisers and Marsh Ltd as well as HBOS.
Now advising regulators, financial services and other firms on risk management, governance, regulation and business ethics, Paul can tell the HBOS story, re-examine his experiences and pull out the lessons to be learned from a risk and regulatory perspective. His analysis and expertise encompasses all the elements of effective risk management, governance, regulation and business ethics: not only structure, framework and process but also, the often-neglected and more important aspects of organisational culture and ethics as well as the professional standards and competence of the risk and compliance managers themselves which has often been a key issue.
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