Credit Union ANNUAL REPORT 202120transaction processing, politically exposed persons andINTERNAL AUDITNotwithstanding the resignation of the Internal Auditupdating due diligence for existing members.Manager (IAM) in December 2020 and the hiring of aCompliance Auditsreplacement in June 2021, Internal Audit issued sevenDuring 2020/2021, the Credit Union’s compliance audit(7) audit reports relating to Death Benefits, End of Dayprogramme focused on the onboarding of new accountsReview, Loans, Ethics, IT Security, IT Governance andto ensure they were in line with regulatory obligations,Cash Management during 2020/2021.the Credit Union Rules, and established policies andWe noted no material breaches in our policies andprocedures.procedures in these areas relating to the Internal AuditData Protection Act (“DPA”)function; however, recommendations were made forThe DPA came into effect in September 2019. In order toimprovement in the control environment.Managementensure compliance, the Credit Union continues to enhancesignified its commitment to improvements which wouldits policies and procedures, amend its internal processesresult in increased effectiveness and stronger internalto ensure it is balancing its obligations under the DPA andcontrols. The Board and external auditor have sight ofprovide ongoing training for its employees. During thethese reports.2020/2021 financial year the Credit Union enhanced itsRISK AND COMPLIANCEAnti-money Laundering (“AML”), Counter Financing ofrisk management framework to ensure compliance withthe DPA through the following initiatives:·Update to internal policies, procedures and processes;·Introduction of transaction slips;·Drafting terms and conditions to govern memberrelationships; andlaws and regulations which govern its operations. The·Selection of a platform to host board packets.Credit Union’s AML Compliance programme is governedEnterprise Risk Management (“ERM”)through a 4-pillar approach - policies and procedures,As the Credit Union continues to grow in pursuit of itsrisk assessment, AML compliance training, and thestrategic goals, it is committed to ensuring its risk arecompliance audit function.appropriately mitigated. To enhance the ERM programme,AML Policies and Proceduresin 2020/2021, the Credit Union with the assistance of anTerrorism (“CFT”) and Counter Proliferation Financing (“CPF”)The Risk and Compliance team continues to ensurethat the Credit Union is in compliance with the variousThe Credit Union continues to enhance its policy andexternal service provider completed risk registers for allprocedure framework through the updates and creationdepartments. The completion of these risk registers formof additional policies and procedures. During the pastthe foundation of the Credit Union’s risk managementfinancial year, the Risk and Compliance departmentframework which will be further enhanced in 2021/2022.created four new procedures namely:·Risk Assessment procedureManagement of complaints process formembers·Existing Due Diligence procedureComplaints received by members continues to be·Politically Exposed Person proceduremanaged by the Risk and Compliance Department.·Ongoing procedureThe management of complaints is now enhancedRisk AssessmentDuring 2020/2021 the Credit Union completed itsremediation of existing members who met the criteriafor “high risk” in accordance with the Credit Union’s RiskBased Methodology. The review of existing members isthrough the use of technology, namely centralising allcomplaints received from members through a ticketingsystem. Information received from the complaints arecommunicated to the various business lines. The Riskand Compliance Department completed an analysis ofongoing and through this programme, the Credit Unioncomplaints received with the intention of providing thecontinues to request updated due diligence from itsmembers, when it is determined to be outdated.business lines with meaningful information to reducemember complaints for 2021/2022.AML trainingThe Risk and Compliance function remains committed toDuring the 2020/2021 financial year the Risk andsupporting the business lines in mitigating risks and forCompliance hosted various training sessions on topicsthe 2020/2021 financial year, did not incur any financialsuch as updated policies and procedures, source of funds,penalties.
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