Saba African Bank gives a great importance to the management of risk and compliance, adopting annually approved policies and methodologies within a clear and specific strategy realizing the importance of risk management and compliance in protecting its reputation, partners and assets. It established a framework for that in addition to educating the staff to be aware of its functions and responsibilities, and to comply with its perspective enabling the bank to be fully prepared for any sudden expectations, and has the ability to mitigate its severity and deal with its results professionally. One of the most important that the bank has adopted is the principles issued by the Basel Committee on Banking Supervision, and compliance with all legislation and instructions issued by the Central Bank of Djibouti.
The Risk and Compliance Department, within its framework, is committed to work independency which ensures the availability of effective procedures to submit adequate information to 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 policies by the Audit and Risk Committee of the Board of Directors, reviewing it periodically, and evaluating the extent of the performance.
Furthermore, the Board of Directors is making great efforts to promoting the internal control systems in the bank qualifying continuously the staff to ensure compliance with all applicable laws, regulations, administrative instructions and legislation, and follow-up of the management’s work, and periodic review of the management and the external auditor with the aim of bringing the institution to a high degree of compliance with the laws, legislations, and regulations issued by the Central Bank of Djibouti, the concerned authorities of state, and international institutions, especially the Financial Action Task Force (FATF) and the Basel Committee. In addition to following up on the necessary periodic reports and their results, and committing to treatment in accordance with what is generally accepted in this regard.
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) that Saba African Bank's compliance with the laws and instructions for combating money laundering and terrorist financing, the recommendations of the Financial Action Task Force (FATF), the bank's board of directors approved the due diligence procedures guide, and the anti-money laundering and terrorist financing policy guide.
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 to ensure compliance with the requirements of local and international regulatory authorities.
Saba African Bank applies the necessary measures to ban 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, to ensure the legality of their activities.
Saba African Bank also applies written policies and procedures for reporting unusual suspicious transactions to the Financial Information Collection Unit 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 used (FCM, TEMENOS) as one of the best world systems.
Saba African Bank has obtained its US IRS identification number (M1E5H2.99999.SL.262); to 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 guide 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 included defining the responsibilities of the Board of Directors, which include:
- Ensuring the management of the bank is going on the right path, and 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 disclose it on time, immediately and properly, while making sure that there is no conflict of interests.
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, hold them accountable, and take the necessary actions to address them and reduce its recurrence.