North International Bank takes all necessary steps to comply with the rules for preventing money laundering and combating terrorism financing as well as complying with applicable sanctions.

NIBANK has developed and implemented a risk-based AML/CFT program comprising written AML/CFT policies, procedures, internal controls and systems, which include but are not limited to the following:

  • A customer identification program and procedures;
  • Procedures to collect and refresh;
  • As appropriate, customer due diligence information;
  • Processes to assess risk at both the program and customer level;
  • Processes and systems to monitor customer transactions and activity;
  • Processes and systems to identify and report suspicious activity;
  • And processes to keep required records.

NIBank Compliance Unit

Compliance Unit Function

  1. Advice

The compliance function should advise senior management on compliance laws, rules and standards, including keeping them informed on developments in the area.

  1. Guidance and education

The compliance function should assist senior management in:

  • educating staff on compliance issues, and acting as a contact point within the bank for compliance queries from staff members; and
  • establishing written guidance to staff on the appropriate implementation of compliance laws, rules and standards through policies and procedures and other documents such as compliance manuals, internal codes of conduct and practice guidelines.
  1. Identification, measurement and assessment of compliance risk

The compliance function should, on a pro-active basis, identify, document and assess the compliance risks associated with the bank’s business activities, including the development of new products and business practices, the proposed establishment of new types of business or customer relationships, or material changes in the nature of such relationships.

The compliance function should also consider ways to measure compliance risk and use such measurements to enhance compliance risk assessment. Technology can be used as a tool in developing performance indicators by aggregating or filtering data that may be indicative of potential compliance problems.

The compliance function should assess the appropriateness of the bank’s compliance procedures and guidelines, promptly follow up any identified deficiencies, and, where necessary, formulate proposals for amendments.

  1. Monitoring, testing and reporting

The compliance function should monitor and test compliance by performing sufficient and representative compliance testing. The results of the compliance testing should be reported up through the compliance function reporting line in accordance with the bank’s internal risk management procedures.

The head of compliance should report on a regular basis to senior management on compliance matters. The reports should refer to the compliance risk assessment that has taken place during the reporting period, including any changes in the compliance risk profile based on relevant measurements such as performance indicators, summarize any identified breaches and/or deficiencies and the corrective measures recommended to address them, and report on corrective measures already taken. The reporting format should be commensurate with the bank’s compliance risk profile and activities.

  1. Statutory responsibilities and liaison

The Compliance function may have specific statutory responsibilities. It may also liaise with relevant external bodies, including regulators, standard setters and external experts.

  1. Compliance programme

The responsibilities of the compliance function should be carried out under a compliance programme that sets out its planned activities, such as the implementation and review of specific policies and procedures, compliance risk assessment, compliance testing, and educating staff on compliance matters. The compliance programme should be risk-based and subject to oversight by the head of compliance to ensure appropriate coverage across businesses and coordination among risk management functions.

Know Your Risk (KYR)

Is the process by which The Bank appetite for high risk. NIBank establish procedures and systematic tasks to identify, evaluate, mitigate, monitor and communicate the inherent risks that could affect the scope of the goals of NIBank.

Within the risk factors taken into account by NIBank, are: Customerr/Client, Product, Channels, Jurisdiction.

An operation (transaction) involves the interaction of all risk factors.

  1. Customer: It’s all individual or corporate that maintains a relationship with the bank.
  2. Products: The product has its own characteristics, purpose and associated risks.
  3. Channels: The client-entity link is developed through the products and these are carried out through different channels.
  4. Jurisdiction: Each jurisdiction has its laws, norms, authorities, culture, criminality, corruption rates and associated risks.

Know Your Customer (KYC)

Customer Due Diligence (CDD) or Know Your Customer (KYC) policies are the cornerstones of an effective AML/CTF program. Put simply, they are the act of performing background checks on the customer to ensure that they are properly risk assessed before being on-boarded. We conduct our KYC with a risk-based approach and NIBank does not establish anonymous accounts. Ongoing Due Diligence (ODD) is performed according to the risk assigned and if required Enhanced Due Diligence (EDD) both are conducted. Our KYC controls include the following:

  • Collection and analysis of basic identity information such as Identity documents.
  • Name matching against lists of known parties (such as PEP’s).
  • Determination of the customer’s risk in terms of propensity to commit money laundering, terrorist finance, or identity theft.
  • Creation of an expectation of a customer’s transactional behavior.
  • Monitoring of a customer’s transactions against expected behavior and recorded profile as well as that of the customer’s peers.