Compliance controlCompliance control
The Bank has a Compliance Control and Financial Monitoring Department (hereinafter in this section the Department), whose main objectives are to build an internal control system to manage regulatory (compliance) risks and to prevent money laundering and the financing of terrorism (AML/CFT) and financing of the spread of weapons of mass destruction (WMD).
The Department ensures that the Bank complies with the applicable laws and Bank regulations on AML/CFT and on the spread of WMD. It also assists the Bank’s divisions in performing tasks related to business operations and business support with respect to regulatory compliance in areas such as managing compliance risk, preventing the use of insider information and market manipulation, managing conflicts of interest and combating corruption.
Recognising the importance and special significance of combating money laundering, the Bank has always singled out this area as one of its highest priorities, where compliance with oversight requirements is mandatory and unconditional.
In 2020, the Department, together with the Bank’s business divisions, implemented a number of innovative digital projects focused on automated solutions and remote communication with clients, which enabled the Bank to make progress towards creating more comfortable working conditions for customers and business divisions in the traditionally conservative area of compliance.
The traditional screening of new (potential) clients, which is mandatory for all financial institutions, now takes less time – a decision is made literally in seconds and without the involvement of a Bank employee. The Bank also eliminated the need for clients to visit a Bank office for an interview, resulting in much faster acceptance as clients. In addition, the procedure for updating client information on an annual basis was simplified: now documents can be sent to the Bank electronically through our remote banking service (RBS)
Through integration with state systems and services, the Bank has begun receiving in digital form the bulk of the information that it needs to comply with the principle of know your customer; this reduces the burden on customers to respond to requests for information.
As a leader in the use of new technologies to combat money laundering, the Bank is taking part in several new pilot projects run by Rosfinmonitoring, and it plays an active role in discussing issues that require the involvement of the banking community. The Bank of Russia also considers VTB to be an institution that makes every effort to achieve the shared goal of keeping out of the financial sector those actors whose goals are to conduct grey transactions, to evade taxes or to carry out shady operations.
The Bank is a permanent member of specialised committees of professional associations: the Association of Russian Banks (the Russia Association), the National Financial Market Council and Rosfinmonitoring’s Compliance Council. As a permanent member, the Bank takes part in the development of legislative initiatives, proposes improvements to regulatory requirements in the area of AML/CFT and compliance, and also – together with representatives of specialised private sector organisations and government agencies – develops integrated solutions and uniform approaches to the implementation of these requirements.
The Department regularly monitors compliance with business ethics and anticorruption requirements. The Bank has established a system for receiving information from employees about violations and corrupt practices, including in terms of conflicts of interest, corruption and violations of business ethics. The Department analyses submissions, determines the cause and provides recommendations to the Bank’s divisions on how to resolve situations and to prevent them from arising in the future.
On a daily basis, the Bank analyses its products and services; regulatory documents, at the request of supervisory authorities; and customer requests, to assess them from the standpoint of possible regulatory (compliance) risks, their potential consequences and mitigation measures. Information concerning regulatory (compliance) risk, with a breakdown by business areas, is reported to the Bank’s designated authorities on a quarterly basis.
In 2020, the Bank took part in the AntiCorruption Rating of Russian Business conducted by the Russian Union of Industrialists and Entrepreneurs, which designated the Bank as a class A1 institution – an organisation or company that exercises the highest level of corruption prevention and demonstrates a minimal corruption risk.