Compliance

Group

Compliance is a multi-dimensional practice with various scopes. Within CIB, the Compliance Group focuses on international best practices and promotes the highest standards of honesty, transparency, and integrity.

CIB has a well-established independent Compliance Group, which demonstrates the Bank’s reliability and helps support the pursuit of growth strategies.

The group protects the Bank from the risk of legal or regulatory sanctions, material financial loss, and loss to reputation resulting from failure to comply with laws, regulations, rules, related self-regulatory organization standards, or codes of conduct applicable to its banking activities. Additionally, the group provides intrinsic benefits including constructive communication, improved overall business practices, and a better understanding of the regulatory environment. The group ensures that CIB adheres to compliance standards to safeguard the Bank against a full spectrum of compliance risks.

Compliance, Policies, and Procedures Division

The Compliance, Policies, and Procedures Division ensures that all controls, laws, and regulations are embedded in the applied policies and procedures, all of which are periodically reviewed to ensure they are up to date. The division is also responsible for reviewing and approving marketing materials, contracts, and customer forms. Over time, the scope of the division has expanded to include monitoring bank products through reports to ensure compliance with policies, processes, and regulations.

2018 Highlights

Following the preventive measures taken by the Compliance Group in 2018, the Compliance Policies and Procedures Division began implementing a risk-based approach to detect any violations through reports and take corrective action with all stakeholders. The practice is considered to be the basis of CIB’s monitoring and testing function, which will be a key focus in 2019.

The Compliance Policies and Procedures Division enhanced the percentage of customer data updates by implementing several processes that encourage e-customers to update their personal data. At the same time, the division ensured that all existing controls and CBE regulations are embedded in the core banking system upgrade along with any new controls needed. Another accomplishment of 2018 involved reengineering initiatives to enhance turnaround time and increase customer satisfaction.

Corporate Governance and Code of Conduct Division

The Corporate Governance and Code of Conduct Division adopts corporate governance guidelines and structures CIB’s governance framework to enhance long-term value for shareholders, employees, the community, and other stakeholders. The division also works to ensure that the corporate governance system is documented, transparent, and understandable. The purpose of this division is to ensure that investors, both foreign and local, customers, employees, and the general public are confident about the ways the Bank is managed and supervised.

2018 Highlights

The Corporate Governance and Code of Conduct Division updated all group governance policies in 2018 to match current international best practices. The division continued to manage relevant staff issues and encouraged the use of the Bank’s whistle blowing policy in cases of suspected wrongdoing. Moreover, the division efficiently managed potential conflicts of interest by reviewing several departments’ restructuring in comparison with the respective job descriptions.

The division also ensured that neither employees nor insiders traded CIB stocks during blackout periods to promote transparency and integrity among all shareholders. Furthermore, the division conducted several induction sessions to raise staff awareness of governance and conduct-related issues, in line with CIB’s strategy to ensure that all employees are continuously trained in topics related to conduct.

In 2018, 10 cases were presented to the Staff Issues Committee; these cases included performance disagreements, mismanagement issues, and violations of the Bank’s code of conduct. All issues raised to the committee were thoroughly investigated, and fair and sound decisions were reached.

AML and Terrorism Financing Division

The Anti-Money Laundering and Terrorism Financing (AML) Division develops, implements, and maintains the AML program across the Bank. The division screens transactions against negative lists and sanctioned countries, a measure that shields the Bank against money laundering and terrorism financing crimes. Additionally, the division maintains records of customers and reports suspicious activities to authorities.

2018 Highlights

In 2018, the AML Division rolled out SAS – the industry’s leading analytics software – to facilitate better monitoring and greater understanding of customers’ behavior.

The AML Division also rolled out the Go AML reporting system that supports secure automated reporting to the Egyptian Money Laundering Combating Unit (EMLCU). CIB’s AML team attended several international seminars in 2018 to remain up to date on AML trends locally and globally and ensure we upheld our standard of consistently enhancing performance and applying the highest international standards and best practices.

Foreign Account Tax Compliance Act Division

The Foreign Account Tax Compliance Act (FATCA) Division ensures correct implementation of FATCA regulations and actively follows up on any new updates or requirements, in addition to reporting annually to the US Internal Revenue Service (IRS).

2018 Highlights

During 2018, the FATCA Division successfully uploaded two yearly reports to the IRS as a single Foreign Financial Institution (FFI) as well as another report as a Sponsoring Entity for CIB Mutual Funds. The division also provided continuous support for different cases to facilitate the smooth implementation of FATCA rules while ensuring customer satisfaction.

CBE Relations Division

The CBE Relations Division acts as a business advisor for all the Bank’s departments to ensure they adhere to all CBE regulations and instructions.

2018 Highlights

In 2018, the CBE Relations Division assured adherence to regulators’ instructions while eliminating any impact on business needs. The division acted as a business partner by participating in meetings held to develop new (mostly consumer) products as well as assisting in structuring credit approval lines to comply with CBE regulations.

2019 Forward-Looking Strategy

Going forward, the Compliance Group plans to enhance the efficiency of processes and turnaround time, support CIB through the group’s divisions, and increase staff awareness of key compliance issues. At the same time, the group will continue to safeguard the Bank against the full spectrum of compliance risks. The group will continue cementing compliance issues by delivering effective education and training programs and fostering the values of knowledge, honesty, integrity, respect, and professionalism across the Bank.

The Compliance Group will continue to adopt a risk-based approach that recognizes that different areas of the business and regulatory issues carry varying levels of regulatory risk. Accordingly, the Bank’s resources can be prioritized and allocated to areas with the highest need to boost productivity.

In 2019, the group plans to complete preparations to implement Common Reporting Standards (CRS) in anticipation of local regulators’ announcement of their target rollout date.