As a bank, we do not want to be used as a channel for perpetrating financial crime or laundering its proceeds.
To mitigate against this risk, we have a clear set of policies supplemented by advisory capabilities, training, surveillance and testing. These include standards for managing fraud, bribery/corruption, and preventing money laundering or terrorist financing, which are implemented by business units and support units in a manner commensurate with the degree of risk faced by the relevant unit.
Overall accountability is the responsibility of the Group Head of Financial Crime and Security Services. The Group Operational Risk Committee regularly receives and reviews report on financial crime, and material issues are raised to the Risk Executive Committee, and if necessary, to the Board Risk Management Committee.
We are members of the Anti-Money Laundering/ Countering the Financing of Terrorism (AML/ CFT) Industry Partnership, a public/ public sector collaboration launched in 2017 to share financial crime risks and typologies, and mitigations.