Main Tasks
The Compliance Unit, as the second line of defence in the internal control system, is responsible for ensuring that the Bank remains compliant with applicable regulatory and legislative provisions. Also, the Compliance Unit has been assigned with AML/CTF tasks provided for in Article 6(4) of Law 4557/2018, which are to be distinguished from the tasks of the Bank in its capacity as the competent authority under Article 6(1)(a) of the same law.
The Unit's main areas of responsibility are as follows:
1. Compliance and corporate governance
2. Ethics
- monitoring compliance with and proper implementation of the Bank’s Code of Conduct, examining all relevant matters;
- providing advice and guidance on the proper implementation of the Code of Conduct;
- receiving, examining and assessing reports of breaches of the Code of Conduct;
- recommending on revisions of the Code of Conduct and/or the issuance of relevant guidance where necessary;
3. Compliance with the anti-money laundering and counter-terrorist financing (AML/CFT) legislation
- monitoring and evaluating the proper and effective implementation of AML/CTF policy and recommending amendments as necessary;
- receiving and evaluating internal information, reports and notifications of unusual or suspicious transactions or indications of ML/TF;
- monitoring compliance by the Bank’s business units with the AML/CTF regulatory framework.
4. Compliance with the provisions of the Anti-Fraud and Anti-Bribery Policy
- developing a framework for the assessment and ongoing monitoring of fraud and/or bribery risks arising from the operation and tasks of each of the Bank’s business units;
- assessing, measuring and managing fraud and/or bribery risk falling within the Bank’ s remit;
- informing and raising staff awareness on the identification, detection and reporting of fraud and/or bribery incidents;
- monitoring compliance with due diligence requirements concerning the Bank's associates and suppliers;
- monitoring the performance of the Anti-Fraud and Anti-Bribery Policy, as well as the procedures adopted thereunder, using compliance indicators and targets;
- maintaining logs of identified or reasonably suspected fraud and/or bribery cases, as well as follow-up actions, including any sanctions imposed; and
- preparing an annual report, submitted to the Governor and forwarded to the Audit Committee, on verified fraud and/or bribery cases, as well as evaluating the Bank of Greece’s overall compliance with the provisions of the Anti-Fraud and Anti-Bribery Policy.
The Compliance Unit comprises the following Divisions:
- Regulation and Corporate Governance Division
- Compliance and AML/CFT Division
- Support and Secretariat Division