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ANNUAL <strong>REPORT</strong> AND FINANCIAL STATEMENTS<br />

FOR THE YEAR ENDED 31 DECEMBER 2015<br />

NOTES TO THE FINANCIAL STATEMENTS (Continued)<br />

4 FINANCIAL RISK MANAGEMENT OBJECTIVES AND POLICIES (Continued)<br />

(d)<br />

Other risks (Continued)<br />

iii)<br />

Compliance risk (Continued)<br />

Who manages regulatory and legal risk<br />

The various departments have the responsibility and accountability of managing regulatory and legal risks<br />

relating to their units on a day to day basis with assistance and oversight from Legal and Risk & Compliance<br />

Departments.<br />

Risk & Compliance Department identifies and monitors the key risks and is responsible for ensuring that<br />

the day to day business controls comply with applicable legislation and are in line with best practice.<br />

How we manage regulatory and legal risks<br />

External legal counsel work closely with business units to identify areas of existing and potential regulatory/legal<br />

risks and actively manage them to reduce the Bank’s exposures.<br />

Senior Management and the Board Risk Management Committee receive the Risk & Compliance Department’s<br />

reports on the status of the Bank’s Compliance<br />

Senior Management and the Board Risk Management Committee receive the Risk & Compliance Department’s<br />

reports on the status of the Bank’s Compliance Risk Framework to enable them to determine<br />

whether it is under control and where not, tracks significant corrective actions to finality. Additionally,<br />

significant exposures under “for or against” litigation are reviewed periodically.<br />

The Board of Directors and Senior Management sets the “tone at the top” for a compliance culture beginning<br />

with concern for what is right (including compliance to policy and the law) in all our business considerations,<br />

decisions and actions.<br />

How we manage regulatory and legal risks<br />

Business unit heads manage day-to-day regulatory and legal risk primarily by implementing appropriate<br />

policies, procedures and controls already in place. The Legal & Compliance departments assist them by:<br />

· Communicating and advising on regulatory and legal requirements, and emerging compliance obligations<br />

to each business unit as required.<br />

· Implementing or assisting with reviews of policies, procedures and training. They do this by independently<br />

monitoring and testing for adherence to certain regulatory and legal requirements, as well<br />

as the effectiveness of associated key internal controls.<br />

· Tracking, escalating and reporting significant issues and findings to Senior Management and the Board<br />

of Directors.<br />

· Liaising with regulators, as appropriate, regarding new or revised legislation, regulatory guidelines or<br />

regulatory examinations.<br />

We have developed robust policies and procedures designed to manage Know Your Customer (KYC) and<br />

Anti-Money Laundering (AML) risks as envisaged in the Proceeds of Crime & Anti-Money Laundering Act.<br />

Our account opening requirements and customer transaction screening procedures meet the stringent<br />

requirements stipulated therein. Reporting of suspicious and other transactions is done as required by<br />

the law and policy standards. We carry out appropriate periodic due diligence on correspondent banking<br />

counterparties, and meet KYC / AML obligations to them continuously. All staff are trained when they join<br />

the Bank.<br />

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