Ben Lawsky, New York State's first Superintendent of Financial Services who is often referred to as the 'heir of Elliot Spitzer', the discredited former New York State attorney, has issued a four-point proclamation about his main prosecuting policy. Two of the points are directly relevant to the wealth management sector: he intends to use the full panoply of his powers to bring the highest possible officials at the next discredited private bank to book, in contrast with the Securities and Exchange Commission which let all individuals at HSBC walk free last December after the corporation signed a deferred prosecution agreement; and he is searching for 'new legal tools' to force regulators who are embedded at recalcitrant banks to do their jobs, unlike the two staff-members of the Office of the Comptroller of the Currency who sat at that bank for two years while money-laundering and terrorist finance took place all around them.

HSBC had to pay the largest ever fine levied by regulators at the end of last year – a consolidated sum of $1.9 billion which cost the group almost 19 days' worth of its pre-tax profits. The OCC staff members ended up paying no penalties at all, as did the OCC itself.