The Bank has established an independent AML and Compliance Function that directly reports to the Board’s Audit and Compliance Committee, in line with Basel and CBB guidelines. The Function consists of four primary sub-functions, including Financial Crimes, Regulatory Compliance, Compliance Assurance and Fraud.
The AML and Compliance function acts as a focal point for all regulatory compliance and for adapting other best practice compliance principles. The Bank continuously strives to improve the level of compliance in all its activities. The Bank’s adopted corporate philosophy is: ‘BBK shall continue its endeavor to enhance shareholders’ value, protect the interests of its customers and other stakeholders, and defend their rights by practicing pursuit of excellence in corporate life.’ Anti-money laundering measures form an important area of the compliance function, in addition to areas of corporate governance, disclosure standards, insiders’/key persons’ trading, conflict of interest, and adherence to best practices.
Compliance with regulatory and statutory requirements is an ongoing process. The Bank is conscious of its responsibilities in observing all regulatory provisions and best international practices in its functioning. Compliance reviews and testing activities are conducted along with other regulatory compliance and compliance assurance activities towards ensuring strict adherence to regulatory provisions and international standards. Compliance and AML activities are performed in accordance to an established risk-based plan, approved by the Audit and Compliance Committee of the Board.
The Bank is committed to combating money-laundering and, towards this end, implements all ‘Prevention of Money Laundering Regulations’ as stipulated in the Financial Crimes Module of the CBB Rulebook and other guidelines issued by the CBB. These regulations and guidelines are consistent with the revised FATF recommendations, ‘Customer Due Diligence for Banks’ paper of the Basel Committee, and best international practices.
The Bank has a documented program for anti-money laundering and combating financial terrorism (“AML/CFT”). The program includes periodic awareness training for employees, automated and risk-based AML/CFT monitoring, record-keeping, suspicious transaction reporting, a designated Money Laundering Reporting Officer (MLRO) and a dedicated financial crime combating team. The AML policy and procedures are reviewed annually and approved by the Board of Directors,
Additionally, the Bank has appointed a designated Fraud Reporting Officer and established a dedicated function within Compliance for managing fraud activities including, ongoing fraud monitoring and prevention, fraud investigation, as well as escalation and reporting to the competent authorities.
The overseas branches in India and Kuwait and the subsidiary, CrediMax, have designated compliance and MLRO functions with direct reporting to BBK’s Group Compliance and MLRO, to ensure implementation of applicable regulatory requirements on a group-wide level.
The Compliance and AML function is subject to periodic independent review and examination by Internal Audit, Central Bank of Bahrain, External Audit/independent third party.