Governments and regulators, in protecting the integrity of the financial system, continue to introduce new measures to address opportunities and challenges arising from technological advances, changing consumer behaviour and preferences and to manage increasing risks of cyber threats and financial crime.
New laws, regulations and standards are also being developed around the world to mitigate the potential impact that business activities may have on the environment and society.
In tandem with increasing regulatory emphasis on the outcomes driven by the reforms, financial institutions are continually assessing and adjusting their policies and processes to ensure compliance and best practices are in place.
As a trusted financial institution, UOB is committed to complying with the laws and regulations in the countries and territories in which we operate.
We have robust protocols and processes in place to guard against all forms of financial crime including, but not limited to bribery and corruption, fraud, money laundering and terrorism financing activities and insider trading. We also respect the laws and regulations pertaining to environmental, social and economic impact, product and service information and labelling and marketing communications which includes advertising, promotion and sponsorship.
In 2018, there was no significant fine, penalty or sanction imposed on the Bank for non-compliance in relation to any of the above.
In addition, our compliance programmes are designed and implemented to comply with international standards such as the Volcker Rule, Foreign Account Tax Compliance Act (FATCA) and the Organisation for Economic Co-operation and Development (OECD)’s Common Reporting Standard (CRS).
In maintaining our values-based compliance culture, we also monitor regulatory and industry developments closely, engage with regulators, policymakers and standards-setting bodies actively, and enhance the compliance capabilities within our organisation continually.
Aligned with the standards and guidance provided in the Basel Committee on Banking Supervision’s Compliance and the Compliance Function in Banks paper, the UOB Group Compliance function is responsible for identifying, assessing, monitoring and managing regulatory compliance risks. It assists the senior management committees and the Board in ensuring that the Group’s activities are conducted in accordance with laws and regulations through periodic compliance reviews. Further, it provides updates on regulatory trends and developments to the senior management committees and the Board regularly.
Anti-Money Laundering and Countering Terrorism Financing
Our Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) framework aims to detect and to prevent the risks associated with money laundering, terrorist financing and sanctions. The framework includes programmes relating to risk assessment, employee training, customer due diligence and transaction monitoring.
We require all employees to comply with UOB’s Group Anti-Money Laundering, Countering the Financing of Terrorism and Sanctions Policy and applicable laws.
We review regularly our framework, policies, procedures, programmes and transaction monitoring systems to ensure their robustness and compliance with regulatory requirements. A dedicated senior management committee has governance oversight of the Group’s AML/CFT- and sanction-related matters. The framework and the associated programmes are also audited by our internal and external auditors.
We also constantly enhance our AML/CFT- and sanctions-related systems and capabilities for the prevention and detection of such risks by harnessing technologies such as machine learning and data analytics.
In addition, we run regular training sessions on AML/CFT and sanctions risk management to help our colleagues across business and support units and our international network be more aware of and understand potential issues on the subject.
Prohibiting Insider Trading
All UOB employees are expected to act honestly and with integrity, including with regard to the information that they obtain in the course of their work. All are required to adhere to the UOB Group Policy on Personal Trading in Securities, which governs the prohibition of insider trading and sets the framework for the management of insider trading risks. They are also required to complete annually an online learning module on insider trading and market misconduct.
We also have in place a pre-trade clearance system that requires employees, who may reasonably be expected to have access to inside information, to make declarations and to seek approval before executing their trades on the stock exchanges. In addition, Group Compliance regularly reviews securities transactions to detect potential violations.
We adopt a zero-tolerance approach to bribery and corruption and our employees are expected to conduct their business activities in full compliance with applicable laws and regulations.
The UOB Code of Conduct, which sets the requirement for all employees to uphold the highest professional and ethical standards, includes our policies relating to anti-bribery such as facilitation payments, restrictions on gifts and entertainment expenses, and conflicts of interest. Our anti-corruption policy also applies to those who represent us, including contract employees and vendors.
New employees are required to complete an online learning module and assessment on the UOB Code of Conduct and the UK Bribery Act 2010. Subsequently, all employees are required to complete a refresher course on both topics every year.
In addition, our whistle-blowing procedures ensure that employees can report any concerns in a private, confidential and secure manner.
Foreign Account Tax Compliance Act (FATCA)
Under the provisions of United States’ (US) tax law, FATCA, non-US financial institutions are required to identify and to report information on assets held by US persons and other non-cooperative entities and individuals to the US Internal Revenue Service. Many countries, including Singapore, have entered into intergovernmental agreements with the US to facilitate the reporting required under FATCA.
We are committed to complying with the provisions of FATCA and to ensuring that the Group meets all applicable FATCA requirements in all the jurisdictions in which we operate. Our governance framework also ensures that the Group continues to comply with FATCA requirements on a business-as-usual basis.
Common Reporting Standard (CRS)
The CRS is a global tax information exchange standard developed by the OECD to prevent offshore tax evasion. The CRS requires financial institutions in participating jurisdictions to identify, to collect and to report to the authorities annually the tax residency information of customers from jurisdictions with which agreements to exchange information are in place.
Our CRS operationalisation programme ensures the Group meets all applicable CRS requirements in all the participating jurisdictions in which we operate.