One of the Bankinter Group's essential corporate issues and the foundation of its organisation is the strict compliance with all legal provisions. Obtaining business targets must be done in a way that is compatible at all times with the compliance not only of regulations in force, but also with the best practices required of its business. Therefore, this issue represents not only a legal obligation, but also an ethical commitment, to Bankinter.
Activities that violate the law and entail relevant reputational risk that can materialise both with customers, and markets, employees and the authorities. This is why managing the risk of regulatory non-compliance is necessary. Non-compliance risk is usually defined as the current or future risk to earnings and capital stemming from violations or non-compliance of laws, rules, regulations, agreements, prescribed practices or ethical guidelines that can lead to sanctions, damages or cancellation of contracts and can harm the company's reputation.
Within the control framework that all credit institutions must have, the regulatory compliance function is thus designed in accordance with international best practices and recommendations as a second line of defense, starting from the responsibility of all business units for regulatory compliance, as a first line of defense, where this compliance function is therefore subject to verification by internal audit, as a third line of defense.
During 2015 the internal institutional framework was strengthened for the compliance function, by creating the Regulatory Compliance Committee, as a senior management body responsible for monitoring the compliance policy for the bank's activities. The purpose of the Regulatory Compliance Committee is thus as a control body on the first line of defense, responsible for executing policies on regulatory matters and regulatory compliance that are established at any given time by the Board of Directors' Regulatory Compliance and Audit Commission.
The Group's organic framework for regulatory compliance is also rounded out with other committees:
The Criminal Prevention and Professional Ethics Committee, which is entrusted with supervising the functioning and compliance with the criminal risk prevention model implemented at the Bankinter Group, as well as exercising disciplinary powers with regard to non-compliances with the Code of Professional Ethics and other internal regulations applicable to the different businesses of Group companies.
The Products Committee, whose mission is to approve the launch, modification and cancellation of the products and services offered to retail customers.
The Internal Control Body, whose main mission is to establish and approve policies on preventing money laundering and financing terrorism, in accordance with Act 10/2010 and its regulatory implementation, which are those which establish the Bankinter Group's preventive framework, as well as ensuring compliance with them.
The Money Laundering Prevention Area, which is part of the Compliance Unit, is responsible for ensuring compliance with the policies and procedures adopted by the company with regard to the prevention of money laundering, as well as analysing any suspicious transactions detected and, where applicable, reporting them to the Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offences (SEPBLAC). The Money Laundering Prevention Area periodically reports its activities to Bankinter's Body of Internal Control and Communication.
