Board Risk and Compliance Committee (BRCC)
ARCC (Audit, Risk and Compliance Committee) was formed in 2014. It was upgraded to Board level in 2018 and divided into two committees: Audit Committee (AC) and Board Risk and Compliance Committee (BRCC). BRCC assist the Board in fulfilling its oversight responsibilities with respect to the risk management, compliance as well as ethics and integrity according to the prevailing law and regulations. In fulfilling its oversight responsibilities, the Committee will perform duties and responsibilities as delineated in the Risk and Compliance Committee Charter.
The responsibilities of Board Risk and Compliance Committee are to:
- Formulate policies relating to risk management that are consistent with the strategic direction and overall risk appetite as set by the Board of Directors.
- Ensure that the Senior Management operates within the risk tolerance limits set and to recommend changes as and when appropriate in line with any significant changes in internal and external environment.
- Monitor and regular review of the effectiveness of Risk Management Policy.
Management Risk and Compliance Committee (MRCC)
Management Risk & Compliance Committee (MRCC) was established by BRCC on 2nd May 2019. The Committee is formed by appointing Risk Managers at each unit of the Bank to track and address the various risks in a timely manner.
The roles and responsibilities of the Committee is to:
- Provide advice to and report to BRCC on all relevant matters pertaining to possible risks,
- Assist BRCC on setting up Risk Management Policy, Framework and Risk Tolerance Limit for the Bank,
- Oversee the adequacy of the controls established by senior management,
- Ensure that proper process in place for the Chairman of the Board and BRCC is immediately informed of any material non-compliance matter or material litigation,
- Obtain information from, and access to Management,
- Ensure all the risks are properly addressed within a specified time limit and Bank’s risk tolerance level.
Enterprise Risk Management & Compliance Department (ERMC)
ERMC Department is responsible for AYA Bank’s Enterprise Risk Management (ERM) framework and advising on compliance and risk management across the branches and all Bank’s business operations.
The role & responsibilities of ERMC Department are to:
- Identify and manage areas of potential risk and to safeguard the assets of the Bank and its shareholders,
- Assess whether the right risks have been identified and are appropriately managed,
- Understand current areas of greatest risk (financial and non-financial) and review these areas on a regular basis,
- Obtain regular updates from management, the Bank’s legal counsel, auditors, and any external parties, as deemed appropriate, regarding audit, financial reporting, risk management and compliance matters,
- Review the adequacy of the Management Information & Intelligence Systems for appropriate management of the Bank’s customers, business – e.g., risks and profitability,
- Periodically review the effectiveness of the Compliance function, including the process of monitoring for compliance with CBM laws and regulations and the results of management’s investigations and follow-ups (including disciplinary action) of any fraudulent acts or non-compliance,
- Review the findings of any examinations by regulatory agencies and any material correspondence with such agencies,
- Review and monitor the effectiveness of the Bank’s controls in the areas of credit, operational and financial risks, legal and regulatory compliance, and financial reporting,
AYA Bank has established compliance approach, policies and functions that contain the fundamental principles to be followed by the Board, Management and Staff.
An independent compliance function is a key component of the Bank’s second line of defense. This function allows monitoring that the Bank operates with integrity and in compliance with applicable, laws, regulations, and internal policies. Similarly, it helps improving in compliance issues, act as a contact point within the bank for compliance queries from staff members and provide guidance to staff on the appropriate implementation. The areas focused by the compliance function includes bribery, money laundering, country sanctions, fair business dealing with the consumers, practices raising ethical issues and including those that could create reputational risk for the bank.
ANTI-MONEY LAUNDERING & COUNTER FINANCING OF TERRORISM POLICY AND INTERNAL CONTROL MEASURES
Following key elements are effective steps to ensure better compliance.
Know Your Customer Policy
Customer Due Diligence Measures
On- Going Monitoring of High-Risk Transactions and Accounts
Reporting of Suspicious Transactions
Reporting of Suspicious Transactions Record keeping
Appointing Compliance Officers
Effective Risk and Compliance Training
AYA BANK AML/KYC Questionnaire