2016 In Review

Compliance

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The Compliance Group is an independent unit that continues to support CIB’s business and operations to enable the Bank to pursue its growth strategies. The group works to ensure CIB adheres to compliance standards to safeguard the Bank against a full spectrum of compliance risk, while reducing the risk of imposed fines by the regulator.

The Compliance Group has five divisions under its umbrella:

The Policies and Procedures Division ensures that all controls, laws and regulations are embedded in the applied policies and procedures, which are periodically reviewed to ensure they are up to date. The division is also responsible for reviewing and approving marketing materials, contracts and customer forms. The Corporate Governance and Code of Conduct Division ensures that a sound corporate governance model is in place and that the Bank adopts international best practices in compliance standards. The division also ensures the appropriate segregation of duties for all positions across the Bank by reviewing updated job descriptions versus organisation charts to detect and escalate cases of conflict of interest. The Anti-Money Laundering and Terrorism Financing (AML) Division monitors transactions and customer account activity and screens transactions against negative lists and those related to sanctioned countries to avoid the Bank’s involvement and shield it against money laundering and terrorism-financing crimes. The Foreign Account Tax Compliance Act (FATCA) Division ensures the Bank and its subsidiaries are consistently in compliance with FATCA regulations and reports yearly to the US Internal Revenue Service (IRS). The CBE Relations Division serves the entire Bank to ensure all banking operations comply with CBE instructions and guidelines.

2016 Accomplishments

In 2016, the Policies and Procedures Division undertook several new preventative initiatives, such as reviewing the supporting documentation of new products and ensuring the required approvals have been obtained to guarantee its compliance with established policies, laws and regulations.

The AML Division managed in 2016 the logistics involved in converting to a fully automated monitoring system using SAS software, the industry’s leading analytics software and solutions provider. The first phase of the program will be launched in 1Q2017 and the second phase in 2Q2017.

The AML Division also succeeded in quickly and efficiently migrating Citibank’s retail portfolio, which was acquired by CIB in 2015, in accordance with CIB’s AML policies and procedures. It also updated in 2016 the risk assessment to evaluate the exposure to operational risk in AML.

In keeping with the AML Division’s ethos of consistently enhancing performance and applying the highest international standards and best practices, the AML team attended several international and local seminars and conferences to keep up to date on AML trends locally and globally. In doing so, three AML officers became internationally certified by the ACAMS in 2016, with more expected to be certified in 2017, making the team one of the highest qualified in the country.

The FATCA Division successfully outlined the accounts acquired in the Citibank transaction. It also sent the yearly reports to the IRS as a Foreign Financial Institution and as a sponsoring entity for CIB Funds. To more effectively keep up with the regulator’s directives, in 2016 a CBE Relations representative joined the FX Committee to ensure the Bank abides by FX allocation regulations. Due to market conditions and ongoing changes during the year, the division had to respond to a substantial volume of daily inquiries and follow special CBE approvals for exceptional cases.

In another milestone for the Compliance Department in 2016, the Chief Compliance Officer was a member of a committee formed by the Egyptian Financial Supervisory Authority to develop the “Corporate Governance Guide for Egyptian Companies,” receiving a certificate of appreciation for efforts exerted in launching the guide.

Goals Going Forward

Going forward, the Compliance Group plans to continue to improve the efficiency of processes and turnaround time, support CIB through the Group’s five divisions and enhance staff awareness of key compliance issues to even better safeguard the Bank against potential risk. The department also plans to ensure adequate controls are in place while maintaining a smooth workflow to boost customer satisfaction.

The AML Division quickly and efficiently migrated Citibank’s retail portfolio, which was acquired by CIB in 2015, in accordance with CIB’s AML policies and procedures.