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NCBFG’s Regulatory Compliance Financial Crimes Policy

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Key Points from NCBFG’s Policy

Based on the provided policy, it appears that NCBFG has implemented a robust framework for managing financial crimes risk and ensuring compliance with regulatory requirements. Here are some key points from the policy:

AML Risk Assessments

• NCBFG conducts quarterly risk assessments to identify and assess new and existing risks related to:
  • Customers
  • Countries
  • Products
  • Services
  • Transactions
  • Delivery channels
  • Operating environments

Compliance Function

• The Compliance Function acts as the Group’s “second line of defence” against compliance risks.
• It provides guidance, training, and ensures mechanisms are in place for entities within the Group to comply with regulatory obligations.

Internal Audit Function

• The Internal Audit Function is separate from both the Business and the Compliance Function.
• It acts as a “third line of defence” by providing independent assurance on the effectiveness of policies, procedures, and controls.

Roles and Responsibilities

• The President and Group Chief Executive Officer (Group CEO) sets the tone at the top and fosters an appropriate culture of AML/CFT compliance.
• The Audit Committee reviews internal and external audit reports.
• The Risk Committee reviews and recommends proposed amendments to financial crimes-related policies.

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