Investor Presentaiton
49
REVIEW OF PERFORMANCE
Looking to the Future
with Confidence
are used to monitor the level of operational risks
and issues in the Group.
Business Continuity Management
The Group has a robust business continuity
management framework in place that allows
quick reaction to any disruptive event to ensure
continuity of operations. Business continuity
plans are reviewed and tested at least annually
across the Group, ensuring seamless service to
the Group's customers and partners during any
potential operational disruptions. The Group has
also established a modern work area recovery site
to provide all required facilities to business and
operational units in the event of regular office
units being inaccessible, along with enhanced
NEO
flexible working arrangements which enable
remote working. Group Operational Risk regularly
conducts risk awareness programmes for all
Emirates NBD employees.
Group Compliance
Compliance risk can be defined as the risk of legal
and/or regulatory sanctions, fines and losses
associated with damage to the Group's reputation
as a result of its failure to comply with applicable
laws, regulations, policies or good practices.
Group Compliance is responsible for assisting the
Group's senior management in designing,
implementing, delivering and supporting a
framework to ensure appropriate measures are in
place to mitigate these risks in all of the
jurisdictions the Group operates in.
Emirates NBD is primarily regulated by the
CBUAE and is required to comply with the laws
and regulations of the UAE as well as those of all
other jurisdictions that the Group operates in.
Emirates NBD also aligns its policies and
procedures with the international industry
practices expected by our correspondent banks.
The Group maintains a good working relationship
with regulators and correspondent banks and
continues to proactively meet with its major
correspondent banks to discuss progress on key
compliance-related initiatives. All relevant
regulatory and compliance matters are regularly
reported and discussed at the Group and Board
committee meetings.
The Group has continued to observe an increasing
level of regulatory activity in the financial crime
compliance space as a result of the 2020
Financial Action Task Force (FATF) Mutual
Evaluation Report of the UAE, as well as a
significant increase in sanctions levied against
Russia by the countries controlling key global
currencies. This has included the issuance of a
large number of circulars, notices and guidance
documents, and the launching of Public Private
Partnerships (PPP) at the Dubai, Abu Dhabi and
Federal levels. The CBUAE has also increased the
level of thematic style reviews in addition to
follow up examinations as part of its risk-based
supervision regime. One of the most significant
regulatory changes introduced by the CBUAE was
the reduction in the timeline for submission of
Suspicious Activity Reports (SARS) from the
industry standard of 90 days to 35 working days
of alert generation. This increased level of
regulatory activity, supervision and oversight is
likely to continue whilst the UAE pursues its
removal from the FATF 'grey' list. The CBUAE has
also been proactive in the conduct of business
area with the implementation of regulations
around areas such as Consumer Protection and
Corporate Governance.
In line with these regulatory changes, the function
continued to enhance its compliance framework
and infrastructure accordingly including changes
to policies, procedures, training, systems, controls
and assurance processes. These include:
1. Continued enhancement of the effectiveness
and efficiency of Group Compliance systems,
with a focus on increasing screening coverage
and efficiency, upgrading AML transaction
monitoring systems to accommodate the 35
working day SAR filing, supporting STP/digital
initiatives and collaborating with FinTechs.
2. Continued improvements to the Group's
mandatory AML and Sanctions Compliance
programmes, tailored to better support the
Group's main businesses taking into account
staff in customer facing/non-customer facing
roles.
3. Revision of Group Compliance Policies
covering AML/CTF, Sanctions, Breaches,
Personal Account Dealing and Conflict of
Interest.
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