Internal Control System

The Internal Control System is organised to comply with the Bank of Russia’s requirements aimed at ensuring efficient business operations, asset and liability management, keeping up the risk level that would not threaten the interests of the bank’s shareholders and clients.

In accordance with international internal control practices, the bank is committed to improving internal control effectiveness at all levels of governance, along all lines of business, and in all divisions, as well as to ensuring compliance of the internal control system with the nature and scale of the bank’soperations.

The key division responsible for an independent assessment of internal control and risk management efficiency is the Internal Control Service which operates in compliance with the principles of continuity, independence, fairness, and professional competence.

The Internal Control Service is committed to the International Professional Practices Framework promulgated by The Institute of Internal Auditors, and strives to comply with these standards in its operation. The Internal Control Service applies a consistent and systematic approach to assessing and improving the efficiency of risk management, control and corporate governance.

In 2013, in accordance with the plan of action approved by the Supervisory Board and orders of the bank’s management, the Internal Control Service carried out over 7,200 routine audits and more than 9,900 random checks.

In 2013, the Internal Control Service completed 30 audits of financial and business operations of subsidiary and affiliated non-credit organisations, and inspected 4 subsidiary banks and 2 foreign representative offices.

In 2013, the Internal Control Service carried out regular independent monitoring of the quality of corporate and individual household loan portfolios; operations of the bank’s business units; registration, investigation and elimination of IT incidents; transaction support by CSC cross-territorial service centres; AML/FT measures; transactions on financial markets; and operations of subsidiary and affiliated non-credit organisations and foreign subsidiary banks.9,10

The problems identified in the internal control system were communicated to management of the bank, branches, corresponding divisions of the Central Head Office and regional banks. The Internal Control Service monitors how the problems are being solved.

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