Sustainability Report 2025
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Compliance Risk Management

A compliance risk management system functions in the Bank as an integral part of the internal control and risk management system. Compliance control is aimed at minimizing the risks of non-compliance with the requirements of the legislation of the Republic of Kazakhstan, regulatory legal acts of authorized bodies, internal documents of the Bank, and applicable international requirements.

Compliance risk management is carried out on the basis of the three lines of defense model:

-     the first line – structural units of the Bank exercising first-level control;

-     the second line – the compliance control unit headed by the Chief Compliance Officer, providing independent second-level control;

-     the third line – the internal audit unit, performing an independent assessment of the system's effectiveness.

The compliance control unit carries out the identification, assessment, and monitoring of compliance risks, maintains a compliance risk register and map, and conducts regular reviews of internal processes for compliance with legislation.

Within the framework of the requirements of the legislation on anti-money laundering, combating the financing of terrorism and the financing of proliferation of weapons of mass destruction (AML/CFT/CPF), a financial monitoring system functions in the Bank, the "Know Your Customer" principle is implemented, and the timely submission of information to the authorized body is ensured.

The Bank complies with applicable sanctions regimes and does not conduct operations prohibited by international economic sanctions.

In the reporting year, the compliance control unit conducted planned reviews, monitored changes in legislation, ensured the automation of certain AML/CFT/CPF procedures, prepared regular reporting to the Management Board and the Board of Directors of the Bank, and conducted training activities aimed at strengthening the compliance culture.