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Paul Moore

Former Head of Group Regulatory Risk at HBOS
    Topics & Types
    Business Strategy

    Paul Moore was the former Head of Group Regulatory Risk at HBOS. He was “dubbed” in the press as “The HBOS Whistleblower”. He was the only senior risk & compliance executive in UK banking sector to speak out publicly after the financial crisis about what he saw from the inside of a bank.

    Paul claimed that Sir James Crosby, when he was the CEO of HBOS, dismissed him for reporting that the sales and marketing culture had become markedly out of balance with risk and compliance systems and that the Board should reconsider its continued strategy for sales growth if it wished to avoid excessive risks to the organisation.

    He maintained that failures in governance, risk management, compliance and ethics 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 as well as the lack of rigorous oversight and challenge by internal control functions, the non-executive and the FSA.

    His influential evidence to the UK Parliamentary Treasury Select Committee in February 2009 was widely publicised in the media worldwide and led to questions in the House of Commons and to the resignation of Sir James Crosby who was then the Deputy Chairman of the Financial Services Authority. In his evidence he wrote “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”.

    In April 2013, following an in-depth investigation into HBOS, The Parliamentary Commission on Banking Standards reported that “The HBOS story is one of catastrophic failures of management, governance and regulatory oversight.” The report described the failure of HBOS as “An accident waiting to happen”, “a colossal failure of management and the Board” and corporate governance which represented “...a model of self delusion, of triumph of process over purpose”. The report described the risk function at HBOS as “...a cardinal area of weakness...” and said it was “...a matter of design, not accident...” by Sir James Crosby and the Chairman, Lord Stevenson. As a direct result, Sir James Crosby gave up his Knighthood.

    Paul will tell you about “The HBOS story and the lessons learned”. He uses this entertaining and educational personal story to explain what happened at HBOS and the key lessons for all types of organisations. He talks about the crucial importance of developing a culture of openness, and the corporate governance to support it, if organisations want to become truly well managed and mitigate major risks.

    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 nearly 30 years of experience in the financial sector in these areas.

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