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Compliance Operations
Compliance Department monitors the
legislation regarding the banking operations
up- to-date, ensures that the legislative
amendments are reflected in the Bank’s
internal legislation and the practices, within
this scope provides written information to
the Bank’s related units on the issue and asks
them to take necessary measures. Afterwards,
Compliance Department monitors the taken
measures, actualized modifications on the
practices and arrangements on the internal
legislation about the issue by the related
units. The Compliance Department, apart from
the legislative amendments, by informing
the related units about the legislative
arrangement drafts regarding the banking,
ensures that the required practices are started
before the arrangement is put into force and
necessary measures are taken on time for full
compliance with the legislation.
Compliance Department operates, within the
scope of the Law n.5549 on the “Prevention
of Laundering of Proceeds of Crime”, the
Law n.6415 on “Prevention of Financing of
Terrorism” and the relevant regulations, with
the aim of fighting more effectively against
the laundering of the proceeds of crime and
the financing of terrorism and of preventing
the utilization of the financial system by the
criminals.
In accordance with the legislation on the
prevention of the laundering of the proceeds
of crime and the financing of terrorism,
required legal obligations are fulfilled, the
compliance of the Bank -on this issue- with
the national and international legislations
is ensured, the obligation of providing
information and document is fulfilled by
ensuring necessary communication and
coordination with the Financial Crimes
Investigation Board (MASAK).
In 2013, the staff of the Internal Control
Department was supported by the recruitment
of the Intern Auditor. Moreover, as a result
of the encouragement of the auditors to get
administrative positions, the Bank maintained
its policy of providing qualified human
resource from Internal Control Department
to the administrative staff. Trainings in and
outside the Bank were organized for the
Auditors performing duties in the Internal
Control Department in order to ensure
that they increase their knowledge on the
legislation and get certification within the
scope of the international standards on
auditing.
Pursuant to the “Regulation on the Audit of
the Bank Information Systems and Banking
Processes by Independent Audit Firms and the
Circular on Governance Statement,” issued
by the BRSA, the Bank’s Board of Directors is
required to present a governance statement
about internal controls on information
systems and banking processes to the
Bank’s independent audit firm. The studies
were carried out to present the governance
statement in January 2014, which covers the
audit period of 2013.
In summary, the Bank’s internal control
activities are carried out in accordance with
the objectives, policies and strategies of the
Bank in an orderly, efficient and effective
manner and pursuant to existing legislation
and regulations. By monitoring the changing
requirements, risks and technological
developments and by taking the necessary
measures related to internal control
operations, the Bank aims to increase the
efficiency of control activities and to reduce
operational risks.
With regard to all activities carried out within
the Bank, the aim is to provide systemic and
organizational arrangements that enable
departments to make controls within their
own organizational entity and at the time of
the execution of transactions; and therefore,
to create an effective internal control system,
to ensure that all personnel understand the
importance of internal control and to create
a corporate control culture involving all
employees.
ASSESSMENT of THE INTERNAL SYSTEMS AND 2013 operatıons
Moreover, regarding the transactions at the
Bank which can be suspicious in terms of
“laundering of the proceeds of crime” or
“financing of terrorism,” after the necessary
investigations are made, transactions which
are deemed suspicious are reported to
Financial Crimes Investigation Board (MASAK).
The Compliance Department represents the
Bank in the MASAK work team formed within
the Banks Association of Turkey.
Regarding the prevention of “laundering
of the proceeds of crime” and “financing
of terrorism,” national and international
legislations are closely monitored. Decisions
taken and applied sanctions by the national
and international institutions and corporations
are followed and reflected in the Bank’s
business practices. The opinion requests of
the Bank’s units and branches on this issue
are met and when necessary the guidance
is given for each transaction. Furthermore,
mutual exchange of information is ensured
with the corresponding banks regarding
the issue. With the aim of following the
international sanctions in a healthy manner,
on the April 2013, the Bank bought a
banned list (Dow Jones-Watch List) in which
the sanction decisions of the international
institutions and corporations (such as; The
United Nations, European Union, OFAC etc.)
are professionally compiled and accordingly
it was started to be used in the queries and
controls made by the Compliance Department.
Moreover, the process in order to integrate
the aforementioned list into the Bank’s VIT
system, continues.
Within the scope of the training activities
and with the purpose of raising awareness
among the Bank personnel on the issue of
“prevention of the laundering of the proceeds
of crime and financing of terrorism,” the
awareness is created through arranged (in
cooperation with the Training Department)
in-class and on-line training sessions for the
Bank personnel.