- New training programs launched in Anti-Financial Crime
- Comprehensive review and amendment of Know Your Customer program
- Increased headcount in Anti-Financial Crime by almost 30% in 2016
As a responsible bank, the way in which we conduct our business is as important as our financial performance. We are committed to supporting the development of effective regulations and procedures at international standards to combat financial crime. We consider this as vital to ensuring the stability of banks and the integrity of the international financial system as a whole; it also helps to protect us from being misused for committing criminal offences.
Anti-Financial Crime (AFC) encompasses protection against financial and reputational losses incurred by financial crimes. We manage this by assessing, controlling, and mitigating risks, which we consolidate in a comprehensive risk management framework that covers Anti-Money-Laundering (AML), Sanctions and Embargoes, Anti-Fraud and Bribery and Corruption.
In response to concerns by the UK Financial Conduct Authority and US regulators regarding the lack of a risk appetite statement, we have now developed one that details the aggregated level of risk that the bank is willing to assume in order to achieve its business objectives. This forms the cornerstone of our risk culture and is communicated globally.
Our AFC function is set up as a matrix structure, with teams focusing on global policy, strategy, and prioritization of strategic goals; a program-wide framework, policy governance, and oversight of AML; Sanctions and Embargoes and Anti-Fraud; and Bribery and Corruption. There are also teams with a regional focus, accountable for the day-to-day management of risk, and those that support our Business Lines and global support and services.
To provide oversight and governance of financial crime risk across all functions and regions, a Global Financial Crime Governance Committee was established in 2015. Chaired by the Global Head of AFC and meeting quarterly, it is supported by regional governance committees, which represent all regions.
Employee training and engagement
Accountability ultimately rests with every employee in the bank, and we have strict policies and procedures, as well as tools to engage employees in implementing, evaluating, and updating policies on a continuous basis. These may include specific local measures related to a particular region’s regulations.
Our Conduct, Organization & Regulatory Education function delivers courses to help employees grow their understanding around anti-financial crime as well as compliance and regulation issues, which are strongly connected to AFC and are part of our Chief Regulatory Office organization.
- Graduate induction week for new joiners in AFC or Compliance departments
- Intern and graduate training for 800 graduates and 1,200 interns
- A new induction process in the Americas, the UK, Asia Pacific, Europe and the Middle East
- Classroom “fundamentals of AFC sessions”
We monitor our portfolio of AFC training annually to ensure that our offering is up-to-date.