Page 34 - 86395_CCB - 2024 Annual Report (web)

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The Bank’s principal risks (continued):

Financial Crime

Description The risk that inadequate controls relating to financial crime could give rise
to fines, litigation, sanctions, reputational damage, or financial loss.

Governance Board Risk & Compliance Committee First Line Risk team
Risk Management Committee Financial Crime Framework (Policy & Standards)
Risk Appetite The Bank maintains a low appetite for Financial Crime risk and strives to ensure that it always
Statement remains within the law and regulation. Whilst the Bank recognises that operational errors can
occur, it maintains zero tolerance for breaches of compliance with applicable anti‑money
laundering laws, regulations and guidance, deliberate facilitation of tax evasion, bribery and
facilitation payments and internal fraud. All material breaches are investigated and reported
to the Board Risk & Compliance Committee in a timely manner. Financial Crime regulation
changes are implemented within the applicable regulatory timelines and staff operate within
the Bank’s documented policies and controls and, where applicable, industry guidelines.

Key Mitigants Adherence to the Financial Crime Framework. High risk customers are approved by the
Undertaking business wide risk assessments. MLRO and subject to annual review.
Customer onboarding incorporating standard Obtaining and using intelligence and
and enhanced due diligence activities. national and international findings.
Function Source of Funds & Receiving reports of suspicious activity
Source of Wealth checks. from any employee in the business.
Individual customer risk assessments which Evaluating any suspicions of money
determine a customer’s risk profile. laundering/terrorist financing.
Third‑party due diligence. Horizon scanning to ensure continued
adherence to regulatory requirements.
Ongoing automated transaction
monitoring and screening. Regular reviews of training content and
training and oversight of the development
Receiving internal suspicious activity reports of staff to ensure up to date knowledge base.
from any employee in the business.
Executive Committee owned KRIs.

Comments Ensuring compliance with all applicable regulatory requirements in a fast‑changing landscape is
a challenge to which the Bank devotes considerable resources. The Financial Crime Framework
is continually reviewed to ensure it meets all requirements and is in line with industry practices.
Annual submission of the MLRO Report to the Board.
The Bank has in 2024 engaged with a new third party provider for the
provision of AML/KYC data and ongoing customer monitoring.