104 VAKIFBANK
ANNUAL REPORT 2015
Within this scope; as per the Regulation on the
Compliance Program regarding the obligations
of the “Prevention of Laundering of Criminal
Proceeds and Terrorism Financing”, in order
to ensure that the Bank’s obligations are
fulfilled; necessary policies and procedures
are structured on the issues of identifying the
customers, classifying them into risk categories
and monitoring them, informing about the
suspicious customer transactions and controls
are made to see if these policies and procedures
are implemented or not, opinion/approval is
given for risky sector and country transactions,
the Financial Crimes Investigation Board
(MASAK) is informed about the transactions
that are considered suspicious in the necessary
investigations and evaluations made within the
framework of a risk based approach about the
potentially suspicious transactions (for the Bank)
detected within the scope of monitoring and
controlling activities or forwarded via channels
like branches to the Compliance Department.
In order to properly follow the international
sanctions, the Bank uses the ban list -
composed of the sanction decisions of the
international organizations such as the United
Nations, European Union, OFAC et al. - in the
investigations and controls.
With the compliance activities carried out in the
Bank’s branches inside and outside the country
regarding “Prevention of Laundering of Criminal
Proceeds and Terrorism Financing”, coordination
of relevant tasks and activities is achieved.
Compliance risks – that may arise from the
regulations in foreign countries – of the foreign
branches that are subject to the compliance
program structured by the Bank in line with the
legislation of the country where activities are
carried out, are monitored by a staff who will
control the compliance with these regulations.
While carrying out its activities, the Compliance
Department works in coordination with the
business units. Within the framework of training
activities, the Bank employee is given in-class
and online trainings to create awareness on the
issue of “Prevention of Laundering of Proceeds
of Crime and Financing of Terrorism”.
LEGISLATION MONITORING AND
EVALUATION ACTIVITIES
Carrying out activities in order to monitor
relevant legislative on the banking activities and
run the compliance process in an effective and
efficient manner.
Regularly monitoring the recent developments
in legislation and banking practices related to
banking activities, interpreting the impacts of
the legislation changes on the banking activities,
within this scope, the measures to be taken by
the Bank and changes to be made in the Bank’s
internal legislation and practices are detected
and thereafter written information about the
issue to the relevant departments of the Bank is
given and necessary measures to be taken are
requested. Furthermore, relevant departments
are informed about draft regulations related
to banking and thus necessary procedures are
initiated before the regulations enter into force.
Legislation Monitoring and Evaluation Activities
also include; monitoring the activities carried out
by the Bank’s relevant departments, measures
taken, changes made in practices, and the
internal legislation regulations, and moreover
coordinating the processes of i) eliminating
deficiencies (as the Department counsels if
necessary) and ii) taking necessary measures
in order to promptly and fully comply with the
legislation, iii) updating the general legislation
and guidelines that will be prepared by the
business units in this context.
Furthermore, an employee is assigned to
monitor the compliance risks – that may arise
from the regulations in foreign countries – in
order to achieve the compliance of the foreign
branches with the legislation of the countries
where they carry out activities.
ASSESSMENT OF THE INTERNAL SYSTEMS AND 2015 OPERATIONS
