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Table 5: Examples of KRIs monitored in the RAF
Оглавление| 1 – Large EU banking group – KRI shortlist Identified four KRIs for financial crime risk type. Anti-Financial Crime (AFC) KRI 1 (Inherent Risk) This indicator captures the weight of transactions which, although linked to sanctioned countries, were processed by the bank because they were either concluded before sanctions were imposed (currently blocked but present in bank’s books) or permissible but exposed to high sanctions risk should regimes become more stringent (e.g. Russia). AFC KRI 2 (Control adequacy) # Payments blocked by 3rd parties This indicator is aimed at measuring the bank’s controls system efficacy against those of another bank’s for sanctions violation, i.e. payment having a nexus to a sanctioned regime. The indicator provides information on transactions that appear to be outside of other market players’ risk appetite. AFC KRI 3 (Control adequacy) This indicator is aimed to increase focus on the transaction monitoring process and understand possible issues in timely finalising the analysis of alerts. AFC KRI 4 (Control adequacy) This indicator provides information on relationships with customers whose risk has not been adequately assessed (yet). At the time of the expiration date, all those KYC positions still not recovered, need to be blocked in order to mitigate the risk. In case of KYC expiration due to unexpected risk events (e.g. increased level of risk due to previously unknown factors like negative news), 60 days’ will be given to review the KYC before proceeding with the block (customer needs to be duly informed about this situation). No new products can be offered until the KYC has been reviewed. |
| 2 – Large EU commercial bank – KRI shortlist Identified eight key risk indicators in four risk areas having high or medium-high residual risks. AML KRI 1 (AML Alerts backlog) AML KRI 2 (KYC Periodic Reviews backlog) AML KRI 3 (Incomplete KYC) Market Conduct KRI (Breaches by employees in permanent list) Customer Conduct KRI 1 (Deal slips with outstanding signature) Customer Conduct KRI 2 (Overduea complaints) |
a
A complaint shall be considered “overdue” when it takes longer than the target time the company establishes as maximum time to address a complaint.
