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Annual Report 2010 - ProCredit Bank

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NRA process does management give its approval<br />

for the innovation to go ahead.<br />

The bank’s Business Continuity Policy ensures<br />

that the bank can maintain or restore its operations<br />

in a timely manner in the event of a serious<br />

disruption. As well as defining the steps to be<br />

taken to restore normal operations, the bank’s<br />

Business Continuity Plan specifies the procedure<br />

for moving critical operations to temporary locations,<br />

the resources that need to be mobilised in<br />

each type of case and the expected cost of disruptions<br />

in specific areas. It also offers guidance<br />

on avoiding disruption in the first place.<br />

Anti-Money Laundering<br />

<strong>ProCredit</strong> <strong>Bank</strong> Romania fully endorses the fight<br />

against money laundering and terrorist financing,<br />

and has implemented the Group Anti-Money<br />

Laundering Policy, which is consistent with the<br />

requirements of German and EU legislation. No<br />

customer is accepted and no transaction is executed<br />

unless the bank understands and agrees to<br />

the underlying purpose of the business relationship.<br />

The Group Anti-Money Laundering Department<br />

(Group AML) conducts an annual survey of<br />

all <strong>ProCredit</strong> banks and updates the group policy<br />

accordingly. In addition, all <strong>ProCredit</strong> banks submit<br />

quarterly reports on their AML activities to<br />

Group AML.<br />

At <strong>ProCredit</strong> <strong>Bank</strong> Romania, responsibility for<br />

AML activities is exercised by the Compliance<br />

Department. According to local regulations, any<br />

transaction (or any series of transactions within<br />

10 days) exceeding the RON or foreign currency<br />

equivalent of EUR 15,000 must be reported to<br />

the local authorities. In addition, any account<br />

activity or attempt to execute a transaction that<br />

arouses suspicion of money laundering, terrorist<br />

financing or some other criminal activity must be<br />

reported. Front-office staff receive intensive training<br />

in how to recognise suspicious transactions.<br />

An additional automated safeguard is provided<br />

by the use of three modules of the AML software<br />

manufactured by Tonbeller AG: Siron Embargo,<br />

Siron PEP and Siron AML. In cases of doubt, the<br />

AML&CFT Subcommittee takes the final decision<br />

on how to handle the suspicious transactions and<br />

suspicious customers reported by the bank.<br />

Capital Adequacy<br />

The bank’s capital adequacy is calculated on a<br />

monthly basis and reported both to the management<br />

and to the Risk Management Committee,<br />

together with rolling forecasts to ensure future<br />

compliance with capital adequacy requirements.<br />

Strong support from our shareholders once<br />

again enabled the bank to maintain a comfortable<br />

capital cushion. During <strong>2010</strong> it received a<br />

total paid-in capital increase of EUR 5.0 million.<br />

At year-end <strong>2010</strong> the IFRS/Basel II capital adequacy<br />

ratio for the bank stood at 16.6%; this<br />

is above the group-wide target of 12%, which<br />

is also the IFRS minimum level required locally.<br />

The bank was issued a rating of BB+ by Fitch<br />

in <strong>2010</strong>.<br />

Risk Management 27

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