Credit Union Annual Report 2021 V2 - Flipbook - Page 22
Credit Union ANNUAL REPORT 2021
20
transaction processing, politically exposed persons and
INTERNAL AUDIT
Notwithstanding the resignation of the Internal Audit
updating due diligence for existing members.
Manager (IAM) in December 2020 and the hiring of a
Compliance Audits
replacement in June 2021, Internal Audit issued seven
During 2020/2021, the Credit Union’s compliance audit
(7) audit reports relating to Death Benefits, End of Day
programme focused on the onboarding of new accounts
Review, Loans, Ethics, IT Security, IT Governance and
to ensure they were in line with regulatory obligations,
Cash Management during 2020/2021.
the Credit Union Rules, and established policies and
We noted no material breaches in our policies and
procedures.
procedures in these areas relating to the Internal Audit
Data Protection Act (“DPA”)
function; however, recommendations were made for
The DPA came into effect in September 2019. In order to
improvement in the control environment.
Management
ensure compliance, the Credit Union continues to enhance
signified its commitment to improvements which would
its policies and procedures, amend its internal processes
result in increased effectiveness and stronger internal
to ensure it is balancing its obligations under the DPA and
controls. The Board and external auditor have sight of
provide ongoing training for its employees. During the
these reports.
2020/2021 financial year the Credit Union enhanced its
RISK AND COMPLIANCE
Anti-money Laundering (“AML”), Counter Financing of
risk management framework to ensure compliance with
the DPA through the following initiatives:
·
Update to internal policies, procedures and processes;
·
Introduction of transaction slips;
·
Drafting terms and conditions to govern member
relationships; and
laws and regulations which govern its operations. The
·
Selection of a platform to host board packets.
Credit Union’s AML Compliance programme is governed
Enterprise Risk Management (“ERM”)
through a 4-pillar approach - policies and procedures,
As the Credit Union continues to grow in pursuit of its
risk assessment, AML compliance training, and the
strategic goals, it is committed to ensuring its risk are
compliance audit function.
appropriately mitigated. To enhance the ERM programme,
AML Policies and Procedures
in 2020/2021, the Credit Union with the assistance of an
Terrorism (“CFT”) and Counter Proliferation Financing (“CPF”)
The Risk and Compliance team continues to ensure
that the Credit Union is in compliance with the various
The Credit Union continues to enhance its policy and
external service provider completed risk registers for all
procedure framework through the updates and creation
departments. The completion of these risk registers form
of additional policies and procedures. During the past
the foundation of the Credit Union’s risk management
financial year, the Risk and Compliance department
framework which will be further enhanced in 2021/2022.
created four new procedures namely:
·
Risk Assessment procedure
Management of complaints process for
members
·
Existing Due Diligence procedure
Complaints received by members continues to be
·
Politically Exposed Person procedure
managed by the Risk and Compliance Department.
·
Ongoing procedure
The management of complaints is now enhanced
Risk Assessment
During 2020/2021 the Credit Union completed its
remediation of existing members who met the criteria
for “high risk” in accordance with the Credit Union’s Risk
Based Methodology. The review of existing members is
through the use of technology, namely centralising all
complaints received from members through a ticketing
system. Information received from the complaints are
communicated to the various business lines. The Risk
and Compliance Department completed an analysis of
ongoing and through this programme, the Credit Union
complaints received with the intention of providing the
continues to request updated due diligence from its
members, when it is determined to be outdated.
business lines with meaningful information to reduce
member complaints for 2021/2022.
AML training
The Risk and Compliance function remains committed to
During the 2020/2021 financial year the Risk and
supporting the business lines in mitigating risks and for
Compliance hosted various training sessions on topics
the 2020/2021 financial year, did not incur any financial
such as updated policies and procedures, source of funds,
penalties.