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Raiffeisen Bank International | Sustainability Report 2018
Management Overview Foreword
of sustainability
Responsible
banker
Fair partner –
Human Resources
Fair partner –
Inhouse ecology
Engaged
citizen
GRI index and
Assurance report
To combat money laundering and the financing of terrorism, RBI has appointed an independent anti-money
laundering officer (reporting directly to the whole Management Board for organizational and disciplinary
purposes) and two deputies and established extensive rules and processes that all employees and relevant
group companies are required to observe. All employees are obliged to check the identity of the customer,
identify the economic owner of the customer, question the purpose and nature of the business relationship,
establish the origin of the funds and examine and record any connections with politically exposed persons
(PEPs), particularly before establishing a long-term business relationship. Furthermore, all of the financial
sanctions that are relevant for the RBI are continually reviewed. Employees are also obliged to take adequate
risk-based measures for the continuous monitoring of the business relationship and to ensure that the business
relationship is consistent with the knowledge about the customer, its business activities and its risk profile,
including, where required, the origin of the respective funds. If it is not possible to fulfill one of these obligations
for a customer, a business relationship may not be established with that customer and any existing business
relationships must be terminated and, depending on the situation, the submission of a suspicious activity report
on money laundering to the Federal Office of Criminal Investigation should be considered.
RBI has taken extensive group-wide precautions and implemented IT-based verification processes to ensure
that all banking business and all transactions are consistent with EU sanctions and that applicable US sanctions
are taken into account. RBI complies with the highest standards and comprehensively meets its obligations with
regard to international financial sanctions and trade restrictions.
Discussions on the topic of better identification of all sectors exposed to economic crime are usually carried
out at Board level, or with the second level of management, and ensure appropriate awareness. The necessary
measures and on-going efforts to provide in-depth training are implemented with the support of local
Compliance departments or the Financial Crime Management departments. These also play a key role in
avoiding corruption and in anti-corruption checks as well as in business activities in sensitive areas. Financial
contributions or contributions in kind to political parties, politicians or related institutions are given only in
accordance with strict rules and with the approval of RBI AG Management Board. Clear regulations in this
regard are enshrined in the Code of Conduct and are monitored by Compliance. Sponsoring, (financial)
support and contributions are also given only to recognized private organizations with impeccable reputations.
RBI has a well-established internal control system that entails documented controls and requirements in internal
governance documents to enable transparency in roles/responsibilities, periodic validation of the adequacy
and efficiency of the controls in place for managing the underlying risks and periodic assessment of the
controls by means of various forms of tests to measure its effectiveness. The reporting procedures in the form of
directives for strategically important topics are a central element and the basis for an effective internal control
system. These directives and instructions constitute our “company law”. They include the assignment of
approval authority for group and company directives as well as department- and division-specific directives,
process descriptions for the creation, quality inspection, approval, publication, implementation and monitoring
of directives as well as regulations for their revision and repeal.
The management of the respective group units is responsible for implementation of the directives. The
“Confirmation of Compliance” process is carried out each year. As part of this process, 58 group units must
confirm that they have followed the relevant policies. If this cannot be entirely confirmed for individual units,
these units must create a roadmap of how the gaps will be closed. Monitoring compliance with these group
regulations takes place within the framework of audits by the group and local audit departments.
A fine was imposed on RBI in 2018 in the context of non-compliance with laws and regulations. RBI has appealed
against this fine; a final decision is still outstanding. One network bank received a warning and four cases were
brought in dispute settlement procedures at another bank; final resolution is still outstanding in each case.