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FINANCIAL HIGHLIGHTS AND RISK MANAGEMENT
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ASSESSMENT OF THE INTERNAL
SYSTEMS AND 2014
OPERATIONS
Opinions, recommendations together with the deficiencies detected as a result of the Internal Control activities are primarily shared and evaluated with the employees performing
these activities. Therefore, it is ensured that both the efficiency of the Internal Control System is increased by taking preventive and supplementary measures and the control
process and related activities are improved.
As a result of these activities, issues that need to be improved, and opinions and suggestions about the enhancement of the processes are included in the Internal Control Reports
and risky issues are shared with the relevant units and the senior management to make sure that necessary action is taken. Furthermore, the Head of the Audit Board is informed
about the detected issues that cause losses for the Bank.
Opinions are presented upon making controls on the adequacy and suitability of: (i) all current/planned (future) activities of the Bank, (ii) new transactions and products, and (iii)
control points in the changing or new created processes.
Procedures and principles of the Internal Control activities are revised in line with the laws, regulations, internation Internal Audit standards and developing requirements so that
the effectiveness of the control activities is increased while the operational risks are reduced.
In order to make sure that the Internal control system functions efficiently and effectively in accordance with the Bank’s targets and strategies; changing needs, risks and
technological developments are tracked. Moreover, efforts continue; to consistently improve the Internal control system, to make sure that staff members at all levels understand
the importance of the internal control, and to increase the corporate control culture.
COMPLIANCE OPERATIONS
The 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 the “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.
Within this scope; as per the Regulation on the Compliance Program regarding the obligations of the “Prevention of Laundering of Proceeds of Crime and Financing of Terrorism”,
in order to ensure that the Bank’s obligations are fulfilled; necessary policies and procedures are structured in 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 Proceeds of Crime and Financing of
Terrorism”, 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 since September 2014, the unit monitors the banking activities and relevant legislation and achieves compliance in between.
Recent developments in legislation and banking practices related to banking activities are monitored, impacts of the legislation changes on the banking activities are interpreted,
within this scope measures that must be taken and changes that must be made by the Bank are detected, and thus written information is given to relevant units of the Bank and
necessary measures are requested and followed.
Within the scope of compliance controls, the compliance risks regarding the Bank’s new products and services and the internal legislation regulations are monitored and evaluated
while activities are carried out in coordination with the relevant business units in order to achieve the compliance of the Bank’s business process with the changes in the
legislation. 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.