Chinese walls

Professional or banking secrecy is a core aspect of our business as a bank. It is also a legal obligation. It extends to any "confidential" information, i.e. information transmitted by the customer or person concerned that is not in the public domain. Confidential information may be circulated within the bank and when in the interests of the bank and/or the customer, but is nonetheless subject to Chinese walls and may not be communicated outside of the company.
Chinese walls are both a concept and procedures aimed at controlling the way in which insider information, confidential or commercially-sensitive information is circulated around the bank.
There are several categories of Chinese walls:
  • first-level Chinese walls that ensure that relations with companies or issuers are kept separate from proprietary market activities and investor transactions;
  • second-level Chinese walls that, within relations established with companies or issuers, ensure any advisory services, financing and credit activities are kept separate;
  • individual Chinese walls that apply to any individual or team working on a sensitive file.
  • Chinese walls prevent the circulation or misuse of insider information and enable the bank to manage conflicts of interest.
The notion also has physical overtones in that it implies the spatial separation of the teams concerned as well as restricted access to their offices and IT databases.
Chinese walls may be breached for professional reasons although breaches are subject to strict procedures that require the prior approval of the Compliance Department and that a record be kept of all the names involved.