Auditor PWC As part of the strengthening of the work to combat money laundering and terrorist financing, the Bank has established a “Financial Crime Prevention” unit consisting of, the Bank´s department for combating money laundering and terrorist financing as well as fraud management. The department is responsible for customer induction and KYC processes (know your customer), as well as ongoing and continuous monitoring and follow-up of suspicious customer behaviour. In addition to the AML framework, the Bank has also established guidelines and procedures which describe measures and business processes to secure proper onboarding KYC-processes. The Bank’s KYC processes includes pre-fraud, AML and credit evaluations intended to prevent acts such as various categories of fraud, identity theft and corruption. All routines are maintained on a continuous basis and subject bi-annual review. The Bank has developed and implemented a pre-fraud tool which helps identifying potential fraudsters and identity thefts. During 2022, the Bank managed to detect and prevent fraud on 1,201 credit applications, preventing potential losses exceeding NOK 175 million. The Bank places great emphasis on organising the practice of the Boards of Directors, senior management and employees to enhance awareness and build expertise on how to prevent financial crimes. Regular training of all employees in AML related guidelines and procedures is a core element in the Bank’s risk management system. All employees at all levels, including Board of Directors and full-time external consultants working for the Bank for extended periods shall complete annual training related to anti-corruption and money-laundering (AML). In 2022, 100 % completed such training, compared to 100 % in 2021. Komplett Bank will continue to prioritize developing and improving its framework to prevent money laundering and financial crime by maintaining policies and guidelines in accordance with regulations and best practice, by leveraging innovation and technology to monitoring and reporting suspicious transaction as through regular AML training of its employees. Below is an overview of Komplett Bank’s organisation and line of responsibilities. Board of Directors CEO Øyvind Oanes Internal auditor EY Election committee Risk and Audit committee Compensation Committee Compliance/ Risk Control AML Compliance Officer CCRO CFO CCO CTO (Interim) COO Komplett Bank / Annual Report 2022 25
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