MORNBFI Vol. 1 - Planters Development Bank

APP. Q-23-c08.12.31QBs’ internal audit and compliancefunctions have important responsibilities inevaluating and ensuring adherence to KYCpolicies and procedures. As a general rule,the compliance function provides anindependent evaluation of the QB’s ownpolicies and procedures, including legal andregulatory requirements. Its responsibilitiesshould include ongoing monitoring of staffperformance through sample testing ofcompliance and review of exception reportsto alert senior management or the Board ofDirectors if it believes management is failingto address KYC procedures in a responsiblemanner.Internal audit plays an important rolein independently evaluating the riskmanagement and controls, dischargingits responsibility to the Audit Committeeof the Board of Directors or a similaroversight body through periodicevaluations of the effectiveness ofcompliance with KYC policies andprocedures. Management should ensurethat audit functions are staffed adequatelywith individuals who are well-versed insuch policies and procedures. Inaddition, internal auditors should beproactive in following-up their findingsand criticisms.Q RegulationsAppendix Q-23-c - Page 6Manual of Regulations for Non-Bank Financial Institutions