Governance and Compliance

Saba African Bank attaches great importance to risk, adopting that in annually approved work policies and methodologies, within a clear and specific strategy, recognizing the importance of risk management in protecting its reputation, partners, and assets. It has established a framework for risk and compliance management and worked to educate its staff of the functions and responsibilities, work commitment through its perspective, which makes the bank fully prepared for any unforeseen events, and has the ability to mitigate its severity, while dealing with its results professionally. The bank adopted the principles issued by the Basel Committee on Banking Supervision, and complies with all legislation and instructions issued by the Central Bank of Djibouti.

The Risk Department, within its framework, is committed to working independently, which ensures the availability of effective procedures to access adequate information for decision-makers at all levels.

The management is also committed to a methodology based on identifying the best methods for dealing with potential internal and external risks, according to specific objectives, with the adoption of a clear, detailed policy by the Audit and Risk Committee of the Board of Directors, reviewing it periodically, and evaluating the extent of its compliance.


For its part, the Board of Directors is also making great efforts to promote the internal control systems of the bank by continuously qualifying staff to ensure compliance with all applicable laws, regulations, administrative instructions, and legislation. It is also appraising the management’s work, with the external auditor; with the aim of bringing the institution to a high degree of compliance with the laws, legislation, and regulations issued by the Central Bank of Djibouti, the concerned state agencies, and international institutions, especially the Financial Action Task Force (FATF) and the Basel Committee, with regular follow-up on the necessary periodic reports and their results, and committing to remedies in accordance with generally accepted principles.

Saba African Bank complies with the requirements of the law (n°110/AN/11/6ème L) No. (n°111/AN/11/6ème L), and (n°112/AN/11/6ème L n°196/AN/02/4ème L), related to anti-money laundering and terrorist financing, in addition to adhering to the recommendations of the Financial Action Task Force (FATF), the principles of (Wolfsberg) and the requirements of the Basel Committee (Know Your Customer). The bank's board of directors approved the due diligence procedures manual, and the anti-money laundering and terrorist financing policy manual.

The Board of Directors of Saba African Bank is also keen to comply with the highest levels of transparency and compliance with the regulations, rules, and guidelines applicable to anti-money laundering and terrorist financing, in accordance with the law and explanatory instructions issued by the Djibouti Government, the Central Bank of Djibouti, and instructions and recommendations issued by international organizations, in addition to the internal auditors of the Bank in reviewing the adequacy of AML/CFT policies and procedures, and their compliance within the Bank, in addition to the role of the external auditor who reviews AML/CFT systems. In this respect, Saba African Bank has adopted and implemented internal policies and procedures to combat the risks of money laundering and terrorist financing and ensure compliance with the requirements of local and international regulatory authorities.

Saba African Bank applies the necessary measures to prevent the following:

  • Dealing with fictitious persons, banks, or institutions.
  • Opening accounts with fictitious or digital names.

Saba African Bank also applies the necessary measures to obtain information that reveals the true identity of customers, and ensures the legality of their activities.

Saba African Bank also applies written policies and procedures for reporting unusual suspicious transactions to the Financial Intelligence Service  of the Central Bank of Djibouti.

The bank retains customer data, correspondence, and files for at least ten years from the date of completing the transaction or closing the account.

The Bank has adopted qualitative training policies for all its staff, as part of spreading the culture of compliance at all administrative levels, with an emphasis on implementing the requirements of international legislation, such as the US Foreign Account Tax Compliance Act (FATCA), in conjunction with the implementation of many training programs at the internal and external levels in the field of anti-money laundering and financing terrorism to provide the bank staff with the latest procedures and practices related to this respect. In order to keep up-to-date with international procedures and standards and to ensure a quantum leap in the field of compliance, the bank uses (FCM, TEMENOS), some of the best systems in the banking world.

Saba African Bank has obtained its US IRS identification number (M1E5H2.99999.SL.262); promoting transparency and credibility and achieving balance in compliance with tax laws.

The bank takes all the necessary actions to identify or re-identify customers; to identify persons subject to US taxation, and to submit financial statements and periodic reports on them to the US IRS after their consent is obtained.

Saba African Bank prepared a manual on banking governance procedures for developing a guide for banking governance rules and reviewing the policies and provisions related to the bank, emphasizing the bank's compliance with managing, and promoting good governance in all the various units and departments of the bank, while the governance framework is based on accountability, fairness, transparency, and responsibility.

The Board of Directors has approved the Administrative Structure of the Bank, and defined the functions and responsibilities associated with the executive boards and committees associated with the Board of Directors, and the formation of the Audit and Risk Committee and the Executive Committee, in a way that guarantees its independent work, and the activation of all internal committees of the executive management.

The governance policy of Saba African Bank, which defines the responsibilities of the Board of Directors, includes:

  • Ensuring the management of the bank is going on the right path, within the framework of the relevant applicable laws, the instructions issued by the Central Bank of Djibouti, and the internal policies of the bank, in a way that guarantees the management of the bank in a safe and sound manner and the preservation of the rights of depositors and the interests of shareholders, employees, and other relevant parties.
  • Ensuring the governance system and internal control systems, are implemented, while reviewing their effectiveness periodically.
  • Ensuring an independent internal audit department and the provision of all necessary requirements are in place.
  • Ensuring a policy that regulates and defines transactions with related parties and the interests associated with them is applicable, and to ensure the implementation of any transaction for any of the related parties and the interests associated with them is applicable fairly and without preference, and to disclose it on time, immediately, and properly, while making sure that there is no conflict of interest.

The Board of Directors works, based on the periodic reports submitted to it by the Audit and Risk Committee and the Internal and External Audit, to review the performance of the bank and evaluate its work, the efficiency of its management, identify deviations and abuses, analyze their causes, identify those responsible for them, hold them accountable, and take the necessary actions to address them and reduce their recurrence.