Compliance

ABN AMRO is committed to further build a compliance function within the bank that is best-in-class in all jurisdictions we operate in and that will serve as a benchmark for the financial services industry.

In 2005, ABN AMRO's compliance organisation grew significantly and undertook several key initiatives:

  • forming a new Supervisory Board Committee called the Compliance Oversight Committee
  • starting a Group-wide employee awareness programme for compliance
  • implementing a new transaction filtering process and revised Client Acceptance & Anti-Money Laundering (CAAML) Policy
  • making the head of Compliance an independent function that reports directly to the Chairman of the Managing Board and the Vice Chairman of the Supervisory Board
  • almost doubling the compliance function of the bank with approximately 300 new compliance jobs
  • further educating and training employees of the bank worldwide in compliance (such as in the identifying and reporting of unusual transactions)
  • incorporating compliance into management's objectives as of 2006 and thus influencing the amount of variable compensation

On 1 January 2005, the compliance function within ABN AMRO adopted a global centralised structure covering all of ABN AMRO's operations and major subsidiaries worldwide. In this structure, compliance officers throughout the bank have separate reporting lines to Group Compliance as well as their local reporting lines.

The main functions and tasks of Group Compliance are to:

  • identify, measure and assess compliance risks
  • assist in managing and mitigating compliance risk
  • educate and train our employees on compliance matters
  • monitor key compliance activities and report appropriately to management
  • coordinate and assist in managing the relationships with regulators
  • provide an annual compliance programme

Governance

The Compliance Policy Committee (CPC) is the governing body responsible for the global coordination of compliance. Led by the Chairman of the Managing Board, the committee makes decisions on key compliance activities and provides a broad oversight of Group Compliance.

Members of the CPC include the Chief Financial Officer and the heads of Group Legal, Group Compliance, Group Risk Management, Group Audit and Group Human Resources, and representatives of all businesses.

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