Annual REPORT
2015-Annual-Report-Financial-Statements
2015-Annual-Report-Financial-Statements
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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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