UOB is committed to complying with applicable laws and regulations in the countries and territories in which we operate. These include requirements relevant to the licensing and conduct of banking or financial businesses, as well as those aimed at preventing financial crimes such as money laundering, financing of terrorism, fraud, tax evasion, bribery and corruption and insider trading.
Group Compliance, an independent function reporting directly to the Group CEO, is responsible for identifying, assessing, monitoring and managing regulatory compliance risks. Group Compliance plays a vital role in promoting a strong compliance culture and ethical conduct across the Group through advisory, active engagement with internal stakeholders and training.
The function also assists Management and the Board in ensuring that the Group’s activities are conducted in accordance with laws and regulations through periodic compliance reviews. It also provides regular updates on regulatory trends and developments to Management and the Board.
Our Group Compliance function is 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 Charter establishes the basic principles and duties of the Group Compliance function, roles and responsibilities of the internal stakeholders, and the relationship between Group Compliance and its internal stakeholders.
Our compliance programmes are also 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).
We have implemented a comprehensive Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) framework which 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. A dedicated senior management committee provides governance oversight on the Group’s AML/CFT- and sanction-related matters.
We review regularly our framework, policies, procedures, programmes and transaction monitoring systems to ensure their robustness and compliance with regulatory requirements. The framework and the associated programmes are also audited by both our internal and external auditors.
The UOB Group Policy on Personal Trading in Securities governs the prohibition of insider trading and sets the framework for the management of insider trading risks. We have in place a pre-trade clearance system to monitor the adherence to the policy by employees who may reasonably be expected to have access to inside information. Group Compliance also reviews regularly securities transactions by these employees to detect potential breaches.
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 training 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 whistleblowing procedures ensure that employees can report any concerns in a private, confidential and secure manner.
FATCA is a US-legislation which requires financial institutions to identify and to report information on assets held by US persons and other non-cooperative entities and individuals.
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.
The CRS is a global tax information exchange standard developed by the OECD to prevent offshore tax evasion. It requires participating jurisdictions to identify, to collect and to exchange tax information annually on residents 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.