BPCE - 2019 RISK REPORT Pillar III

11

NON-COMPLIANCE AND SECURITY RISKS

FINANCIAL SECURITY

Financial security 11.2

Organization

Financial security covers anti-money laundering and terrorist financing (AML-TF) measures as well as adherence to international sanctions aimed at individual persons, entities or countries.

BPCE’S INVOLVEMENT IN THE PREVENTION OF MONEY LAUNDERING AND TERRORIST FINANCING Groupe BPCE works to prevent money laundering and terrorist financing through: Corporate culture Promoted across all levels of the company, corporate culture is built on: customer relations principles aimed at preventing risks, which are formalized and regularly communicated to the employees; • a harmonized, biannual training program for Group employees, and specialized training for the Financial Security function. • Organizational structure In accordance with Groupe BPCE’s charters, each institution has its own financial security unit. The Risk division has a special department that oversees anti-money laundering and terrorist financing procedures, defines the financial security policy for the entire Group, prepares the various related standards and procedures (and has them validated), and ensures that anti-money laundering and terrorist financing risks are incorporated in BPCE’s new products and services approval procedure. Specialized processes In accordance with regulations, banks have methods for detecting unusual transactions that are specific to their risk classification. These can be used, if needed, to conduct closer analyses and to submit the required reports to Tracfin (French financial intelligence agency) as promptly as possible. The Group’s risk classification system incorporates the “at-risk countries” factor when addressing money laundering, terrorism, tax fraud and bribery. The system was also reinforced with the establishment of a database and automated scenarios specifically targeting terrorist financing. With respect to compliance with restrictive measures related to international sanctions, Group institutions are equipped with screening tools that generate alerts on customers (asset freezes on certain individuals or entities) and international flows (asset freezes and countries subject to European and/or US embargoes). Supervision of operations Internal reports on the prevention of money laundering and terrorist financing are submitted to company directors and governing bodies, as well as to the central institution.

HIGHLIGHTS The Group Financial Security department hired additional staff in 2019 for the purpose of actively overseeing the function as whole. The permanent control system was reviewed and enhanced.

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RISK REPORT PILLAR III 2019 | GROUPE BPCE

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