The Compliance Control and Financial Monitoring Department assists the Bank’s governing bodies with the effective management of regulatory (compliance) risks (risks resulting in losses due to non-compliance with the legislation of the country of registration, the Bank’s regulations, standards for self-regulatory organisations, as well as the risk of losses resulting from the application of sanctions and/or the impact of other measures on the part of the supervisory authorities).
Regulatory risks also include the risks of money laundering and the financing of terrorism (AML / CFT), as well as financing the spread of weapons of mass destruction (WMD).
The Compliance Control and Financial Monitoring Department:
- Ensures a unified approach to internal (compliance) control, AML / CFT and preventing the spread of WMD within VTB Group’s credit and non-credit financial organisations;
- Carries out the functional coordination of the activities of credit and non-credit financial institutions that are part of VTB Group in fulfilling their requirements in terms of internal (compliance) control, compliance with international sanctions concerning AML / CFT and the spread of WMD in accordance with the basic principles of managing VTB Group and taking into account the legislative provisions in the country of registration / location of the relevant VTB Group credit or non-credit financial institution.
Main tasks in terms of internal (compliance) control
- Ensuring that the activities of VTB Group credit and non-credit financial institutions are in compliance with the legislation of the country of registration, internal regulations, standards of self-regulatory organisations and common business practices;
- Ensuring effective management and minimisation of regulatory (compliance) risk and monitoring the performance of the regulatory (compliance) risk management;
- Coordinating and participating in the development of a set of measures aimed at reducing the level of regulatory (compliance) risk;
- Creating and maintaining an effective system of governance information and reporting;
- Coordinating activities undertaken to meet the requirements of the United States Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS);
- Preventing the involvement of VTB Group companies or employees in unlawful activities (including corruption, improper use of insider information, market manipulation, etc.).
Main tasks in terms of internal control for the purposes of AML / CFT and preventing the spread of WMD
- Ensuring compliance with legislation in the area of AML / CFT and in terms of preventing the spread of WMD;
- Organising an effective internal control system for AML / CFT and for preventing the spread of WMD that is aimed at strengthening VTB Group’s position in financial markets, expanding the scale of its business, and improving the performance of operations and the quality of customer service;
- Minimising the risk of customer transactions involving money laundering or terrorist financing, as well as the risk of non-compliance with international sanctions;
- Avoiding involving VTB Group employees in money laundering, the financing of terrorism and the financing of the spread of weapons of mass destruction.
In the context of measures aimed at the effective development of the systems of internal (compliance) control and AML / CFT and preventing the spread of WMD within VTB Group, the Compliance Control and Financial Monitoring Department interacts with the Coordination Commission on Compliance and Internal Control for the Purpose of Preventing Money Laundering and the Financing of Terrorism (under the VTB Group Management Committee), which includes the following tasks:
- Developing common principles and standards;
- Introducing best practices within VTB Group;
- Sharing information among VTB Group companies and coordinating those companies;
- Improving the general professional capacity of experts.