Compliance, Anti-Money Laundering, and FATCA

This ensures that, across the entire spectrum of our areas of activity, the Bank and its stakeholders are protected as comprehensively as possible from business risks. We value most our reputation and the fact that we are trusted by our shareholders, our clients, our employees, our business partners, and members of the communities we serve.

Business or compliance risk, which can be defined as “the risk of regulatory or legal sanctions, material financial loss, or loss to reputation a bank may suffer as a result of its failure to comply with laws, regulations, rules, related self-regulatory organization standards, and codes of conduct applicable to its banking activities’, is addressed and managed within the Bank through its compliance function and its component system and program.

Under Monetary Board Resolution No.116 dated 20 January 2011, BSP Circular 747 Series of 2012 on the Revised Compliance Framework for Banks, effective implementation of the compliance function requires establishment of a robust, dynamically- responsive, distinctly-appropriate compliance system, and a formal, defined compliance program.

The compliance system is critically important in identifying, evaluating, and addressing the regulatory and reputational risks while the enterprise-wide compliance program helps the Bank to look at and across business lines and activities of the organization as a whole and to consider how activities in one area of the Bank may affect the business or compliance risks of other business lines and the entire group/enterprise.

The compliance program also helps the Board and management in understanding where such regulatory and reputational risks in the organization are concentrated, provide comparisons of the level and changing nature of risks, and identify those control processes that most need enhancement.

Oversight of the management of the Bank’s business risk and implementation of its compliance function is the responsibility of our Board of Directors, through the Audit Committee. At the management level, the compliance function is carried out by the Compliance Office, led by our Chief Compliance Officer.

Read the full biography of the Chief Compliance Officer.

The Compliance Office oversees the implementation of the Bank's enterprise-wide compliance programs. These programs take into account the size and complexity of the Bank, the relevant rules and regulations that affect its operations, and the business risks that may arise due to non-compliance. By using regulatory and self-assessment compliance matrices, compliance measures are formulated to mitigate identified business risks and tested to ensure effectiveness.

The Compliance Office is currently organized to cover Regulatory Compliance, Corporate Governance, Anti-Money Laundering Compliance, FATCA Compliance, and the Data Privacy Office. Considering the rapid developments in the regulatory sphere as well as the growing complexity of bank products, services and transactions, the Compliance Office evolves in its coverage of compliance practice areas to anticipate and meet forward challenges. Enhancement of our compliance function’s scope and domain is redefined for new and emerging sources of compliance risk.

The Compliance Office is also empowered by 23 Group Compliance Officers (GCOs), who are embedded in operational units throughout the Bank. The GCOs are charged with enforcing compliance office initiatives, as well as providing timely reports to the compliance office.

Overall enforcement is through self-regulation within the business units, and independent testing and reviews conducted by the Compliance Office and Internal Audit. Results of these reviews are elevated to the Board’s Audit Committee and Corporate Governance Committee, with respect to governance issues.

The Compliance Office applies a three-layered compliance testing and monitoring process, which includes unit self-assessment testing, conducted by GCOs; independent random testing, performed by the compliance office; and independent periodic review by the Bank’s Internal Audit unit, whose results are reported regularly to the Audit Committee.

The Compliance Office promotes adherence and awareness to laws, rules and regulations by electronically posting information and documents in a compliance database that is accessible to all employees. Regular meetings are conducted by the Compliance Office with the GCOs to discuss the impact of new regulations, decide on the required compliance measures and amend compliance matrices as necessary. Through continued liaison and dialogue with regulators, the Compliance Office ensures the prompt dissemination of new regulations and other developments affecting bank operations