case 01
Summary
The CEO returned the completed draft AML report for revision. Having the facts at his disposal, the whistleblower refused to comply and lodged a complaint with the CEO, the CEO’s deputy, and the owner’s integrity expert.
01
What was uncovered
Lack of a filing system and the illegality of internal regulations. Company management deliberately weakened the internal control system. The owner’s reporting system was inoperable.
02
What wrongdoing occured
Violation of the Hungarian National Bank’s anti-corruption regulations and recommendation, as well as resolutions of the Budapest City Council. Escalating bullying by the CEO. The CEO’s unlawful instruction to fill out the annual AML report with false data. The unlawful dismissal of two internal auditors and one compliance officer.
03
What consequences followed
Dr. Pinter was unemployed for a year and a half before he was finally able to find a job – in a different position.
04
Whistleblowing timeline
AFTER TWO INTERNAL AUDITORS, THE WHISTLEBLOWER WAS ALSO FIRED
The financial institution operated without a filing system in Budapest
The CEO made a serious mistake when he seated the company’s internal auditor and the head of corporate security in the same room. Before long, an excellent professional relationship developed between them. The internal auditor told Pinter that his predecessor had been removed for inexplicable reasons, while he himself had uncovered several instances of misconduct by senior management within a few months. When this internal auditor was also put under pressure, Pinter tried to defend her, but was unsuccessful.
It was not part of the security manager’s duties to prepare the annual money laundering report for the Hungarian National Bank; this was not included in his job description either. The CEO therefore – while keeping his salary unchanged – assigned him the task of handling compliance duties as well. As a qualified banking lawyer, he knew how important the annual AML reports are to the financial system. He was also aware that the person preparing the report bore financial responsibility for its content. Yet he was not concerned, as the company’s deputy CEO had previously served as an internal auditor at a renowned Austrian bank and could be consulted if necessary.
The deadline for the AML report was the end of 2018, but the CEO returned the completed draft for revision. Armed with factual evidence, Pinter refused to comply and lodged objections with the CEO, the CEO’s deputy, and the owner’s integrity expert. In the end, he was not dismissed in the same manner as the internal auditors. The company was reorganized shortly thereafter, eliminating Pinter’s position. He filed a labor lawsuit over his dismissal, but it was unsuccessful. The presiding judge was unable to obtain the internal correspondence proving Pinter’s case, as it had been destroyed in the meantime. The previously eliminated position was reinstated shortly thereafter.
timeline
- NOVEMBER 2016
Dr. Pinter has been hired as corporate security manager at DHK Financial Services Inc.
- FEBRUARY 2017
First risk alert to the CEO.
- MARCH 2017
Reports to the CEO regarding the lack of a filing system and the illegality of internal regulations.
- MAY 2017
Start of mobbing from the CEO.
- AUGUST 2017
Third risk alert to the CEO.
- OCTOBER 2017
Certified expert in anti-money laundering and countering the financing of terrorism
- DECEMBER 2017
Start of compliance tasks.
- JANUARY 2018
Escalating bullying by the CEO.
- FEBRUARY 2018
Fourth risk alert to the CEO.
- FEBRUARY 2018
The whistleblower’s unfounded verbal warning.
- MARCH 2018
The whistleblower’s unfounded written warning.
- MAY 2018
Report on Risks to the Chairman of the Board of Directors.
- JUNE 2018
Statement regarding flaws in the draft AML regulations.
- NOVEMBER 2018
Receipt of the Budapest Institute of Banking Compliance Expert Certificate.
- NOVEMBER 2018
Termination by the employer on November 22.
- DECEMBER 2018
Complaint filed to the court regarding the unlawful termination of the employment. After a year and a half of unemployment, Dr. Pinter landed the best job of his life.
THE WHISTLEBLOWER
For years, Dr. Pinter had been urged to accept the offer to become the head of corporate security at the capital’s only company classified as a financial institution. The reason he finally agreed was that the Budapest Municipal Government had dissolved the company where Pinter had been providing professional advice to all of the capital’s corporate security directors.
Pinter joined DHK Financial Inc., a company owned by the City of Budapest, as Head of Corporate Security in November 2016. His immediate supervisor was the CEO, while his professional supervision was provided by the head of corporate security at the direct owner, FOTAV Inc.
WHO LOST WHAT AND WHO WON WHAT
Neither the internal auditors nor the whistleblower were able to find employment for years. While unemployed, they took part in retraining programs so they could take on other jobs.
It was never revealed why the company’s management had weakened the internal audit system.