Enterprise governance and compliance

COMBATING MONEY LAUNDERING

Nedbank Group remains committed to combating money laundering and terrorist financing through various policies and procedures designed to ensure that statutory duties, regulatory obligations and agreed standards are met. The Business Risk Management Forum, a Group Exco subcommittee, ensures consistent implementation of the Money-laundering Control Programme throughout the group. In 2008 the following deliverables were achieved:

• There was ongoing restriction on clients whose records reflect as ‘not verified’ after a specified period following account opening. At 27 December 2008 altogether 126 190 not-verified records had been restricted and the remaining 31 329 not-verified records were in the bank’s restriction process.
• Training in respect of anti-money-laundering (AML) and the combating of the financing of terrorist and related activities (CFT) remains a high priority. At the end of December our training statistics were as follows:

  –	14 535 of the selected 27 511 employees had completed the Awareness Training for AML/CFT over the past 24 months.
  –	14 903 of the 18 180 retail employees had completed the Money-laundering Control Basic Training.
  –	3 285 of the 5 972 corporate employees had completed Money-laundering Control Specialised Training for Corporate and Merchant Banking.

• The Awareness Training for AML/CFT (an eLearning intervention) was updated to include legislative amendments. The training intervention has been rolled out to the group and forms part of Nedbank’s ongoing training requirement.
• Annual directors’ training in respect of money-laundering and terrorist-financing risk management was developed and implemented to meet SARB and FIC obligations and international requirements.
• The Financial Action Task Force/Eastern and Southern Africa anti-money-laundering group mutual evaluation of South Africa’s anti-money-laundering and counter-terrorist financing regime onsite meeting was held at Nedbank on 11 August 2008. Nedbank was an active participant in the evaluation process.
• The group-level Policy for Anti-money-laundering and the Combating of the Financing of Terrorist and Related Activities, and the Policy for Client Acceptance, Maintenance and Monitoring were updated as part of the annual review.
• Guidelines were developed for employees dealing with politically exposed persons, non-governmental organisations, non-profitable organisations and beneficial ownership.
• A Sanctions Programme was initiated through which Nedbank has implemented a governance forum and structures relating to policies/guidelines on sanctions lists. A process has been developed to govern key decisions relating to the development and approval of sanctions lists to assist business with decisions regarding positive matches against the sanctions lists.
• A Client Identification and Profiling Project was initiated to proactively profile clients during the client takeon process and to maintain and update the client risk profile as each client’s risk profile changes.
• A Crossborder Monitoring Project was initiated to address regulatory compliance for all crossborder transactions.
• There were positive interactions with the regulator and the supervisors, contributing to sustainable trust relationships that are beneficial to all parties.