The in-house system for prevention of legalization of proceeds from crime or financing of terrorism (AML/CTF) of JSC Ukreximbank is headed by the Chief Compliance Officer of the Bank, Member of the Board.
Chief Compliance Officer of the Bank is independent in his activity and accountable only to the Chairman of the Board. Chief Compliance Officer of the Bank supervises, coordinates and controls the activity of Compliance Control Director and of compliance control departments of the Bank.
Compliance Control Director facilitates activity coordination of compliance control departments of the Bank.
Compliance control departments ensure due functioning of the system of internal controls of compliance with the banking, the AML (financial monitoring) and the currency laws in the following fields:
- prevention of and counteraction to legalization (laundering) of proceeds from crime, terrorism financing and financing of proliferation of weapons of mass destruction (AML/CTF/CFWMD);
- conduct of currency transactions and execution of currency controls;
- management of financial monitoring compliance risks;
- prevention of the risky activity, which is challenging the interests of depositors or other lenders of the Bank.
Internal Audit Control
The Bank’s internal audit unit is the Internal Audit Division.
The Internal Audit Division ensures that the Bank’s policies conform to the effective law and regulations as well as to professional norms and ethics. The system of internal controls for which the Internal Audit Division is responsible includes but is not limited to operations, accounting practices, taxation, regulatory compliance, documentary compliance, risk management and IT systems.
The Internal Audit Division on annual basis shall audit the compliance of the activities of compliance control departments and other units of the Bank as well as its regional branches with all legal requirements in the field of prevention of legalization of proceeds from crime/financing of terrorism (including the adequacy of steps taken by the Bank in respect of managing the risks of legalization of proceeds from crime/financing of terrorism).
Based on such audit the Internal Audit Division shall issue its opinion and recommendations for the management of the Bank.
The Internal Audit Division is subordinated to, controlled by and reports to the Supervisory Council of the JSC Ukreximbank.
In accordance with the effective Ukrainian Law, the National Bank of Ukraine (the NBU, the regulator) on regular basis inspects the Bank’s compliance with the financial monitoring legislation and requirements.