First of all, all employees should establish the business philosophy and compliance culture of compliance management.
Let all employees realize that compliance management and compliance culture construction are a major event in enterprise management. It's not what regulators want me to do, but what we should do ourselves and consciously do. Because compliance has a positive correlation with the core elements of bank operation, such as cost control, risk control and return on capital, compliance can create value for banks, and an effective compliance culture will virtually eliminate compliance risks. Compliance management and compliance culture construction are the needs of standardizing business behavior, curbing cases of violation of discipline, comprehensively preventing risks and improving management level; It is urgent to improve the system management system and prevent risks from the source; This is an important guarantee to implement Scientific Outlook on Development and realize the new development goals of rural credit cooperatives. We must let the concept and consciousness of compliance penetrate into the blood of employees in the whole society, penetrate into every post and every business operation link, urge all employees to abide by laws, rules and standards when carrying out business management, strive to cultivate employees' awareness of compliance, promote compliance concepts such as everyone is responsible for compliance, take the initiative to comply, and create value through compliance throughout the bank, and advocate moral values or codes of conduct and corporate culture of honesty and trustworthiness.
The second is to establish and improve the organizational mechanism of compliance management.
We should fully understand the importance of setting up the Compliance Department, strive to overcome the difficulties of few people, heavy tasks and tight time, set up an independent and powerful Compliance Department, and attach great importance to the construction of the Compliance Department. Compliance professionals should not only have strong professional qualities, but also have strong personal qualities. Select personnel with high professional quality, corresponding technical qualifications and business ability to enrich the compliance management team and cultivate and bring up a high-quality professional team. The organizational mechanism of compliance management must implement the responsibility system of the top leader, implement the responsibility system at different levels, clarify the pivotal position of the compliance department in the organization, and clarify the relationship between the compliance department and the business department: the first line of defense for the business department to implement effective self-discipline and compliance control, and the second line of defense for the compliance department to implement professional compliance management before and during the event; As the main channel connecting the internal management and external supervision rules of banks, the Compliance Department decomposes the supervision rules, risk tips and supervision opinions into various business departments or other back-office support departments, and all business departments actively seek the support and help of the Compliance Department, actively provide compliance risk information or risk points, and cooperate with the Compliance Department in risk monitoring and evaluation; Compliance departments should help business departments manage compliance risks by providing constructive opinions, provide compliance support for banking business and product innovation, and minimize legal risks brought by business innovation.
Third, formulate a good system with strong execution.
For a long time, compliance risk management lacks a unified, complete, comprehensive and scientific supervision system and operating procedures. Many regulations are rough, rough and vague, lacking maneuverability. When implementing the system, there are some bad phenomena, such as replacing management with trust, replacing system with habit, and replacing discipline with affection. Compliance management calls for scientific, reasonable and perfect rules and regulations and operational procedures, and it is necessary to strengthen the implementation of rules and regulations to reverse the long-standing situation of unclear responsibilities and difficult implementation of responsibilities. In terms of identification, quantification, evaluation and solution, it is necessary to make timely, necessary and scientific and reasonable improvements to the past rules and regulations and operation methods. Rules and regulations should not remain unchanged for many years. When formulating rules and regulations, we must be targeted, specific and operable. In the formulation of business rules and operational procedures, it is necessary to clarify the normative requirements for sorting, integrating and revising the internal system, and the new system should have the necessary compliance prediction to solve the institutional basis of compliance risk management from the source. We must change the way the rules and regulations of administrative institutions are formulated, and we can no longer stipulate the relevant operating standards of enterprise management in general. We must follow the good practices of financial enterprises and formulate business policies, behavior manuals and operating procedures that can be used by personnel in various positions. Rules and regulations must cover all customers, products and services, and must cover the behavior and ethics of all employees. Through continuous revision and improvement at the system level, we have formed a clear working standard of obeying the law in everything and strict compliance management discipline everywhere, making compliance management a conscious behavior of all employees in the bank.
Fourth, strengthen employee compliance training.
Senior managers, compliance managers and other personnel are the three levels of compliance culture construction. As a grass-roots business unit of the Associated Press, it should organize and formulate a continuous and effective compliance risk training and education plan, and implement the literal requirements and spirit of laws, regulations, standards, compliance policies, compliance awareness and compliance responsibilities applicable to banks into business policies, behavior manuals and operating procedures. According to the principle of full participation, the compliance management personnel and other personnel should be educated and trained, which should be systematic, targeted, professional, practical and diverse. For compliance management personnel, it is necessary to strengthen the training of new laws and regulations, adhere to the cultivation of professional feelings of seeking truth from facts, being objective and fair, being honest and clean, and ensure that employees have the professional qualities they deserve; Be responsible for providing training to other employees on relevant laws, regulatory provisions and industry standards during operation and implementation, including compliance training and testing for new employees; According to the changes of applicable laws, regulations and norms, carry out corresponding training and education with the times; It is necessary to strengthen the positive and negative education, vigorously publicize the advanced models of law-abiding, conscientious, diligent and honest, and promote healthy trends. At the same time, analyze typical cases, openly deal with typical cases and those responsible for violations of discipline, and give warning education to employees. Through multi-level compliance training, the atmosphere of compliance culture will be gradually formed throughout the jurisdiction to ensure the implementation of internal and external relevant regulations.
Fifth, strengthen the inspection and supervision of compliance management.
From the perspective of sustainable development, the compliance operation of banks must realize the effective combination of internal control and external supervision. On the one hand, strengthen information disclosure, improve transparency, and use social forces to supervise enterprise management; On the other hand, strengthen on-site inspection and off-site supervision to further promote self-discipline construction. When performing the functions of inspection and self-discipline, the division of responsibilities of all departments should be clear and closely coordinated to form a joint force. The supervision department is responsible for leading the organization to check and deal with violations of discipline and case clues; The business department is responsible for implementing the operational risk inspection of operating institutions, the special inspection of credit corporate customers' business, the special governance activities of personal loan operational risk and the rectification measures of various businesses under its jurisdiction, and strengthening the system to sort out and improve; The personnel department is responsible for checking the exchange and rotation of personnel in important positions and implementing the compulsory vacation system; The Security Department is responsible for investigating fraud, theft, robbery and other cases, and carrying out special inspections such as gun management, escort, warehouse storage and video surveillance in business institutions. It is necessary to focus on rectification of key businesses, key links and key departments. The first is to manage key business. We will focus on tackling new business management loopholes such as fake car loans, fake housing mortgage loans, fake mortgage loans, fake pledge loans, handling bill business in violation of regulations, using false information to obtain and misappropriate credit funds, using fake hands to renew fake seals and other means to steal deposits from units and individuals, and using current accounts and interbank accounts in the system to steal funds. The second is the key link of management. Focus on the key links such as credit authorization, teller safety certification card, important blank voucher management, treasury and mantissa box, inquiry and reconciliation, rotation and vacation of personnel in important positions, video inspection, and gun and ammunition management. The third is to manage key departments. The focus is on credit management, corporate business, personal business, financial accounting, security, legal affairs, personnel and other departments.
Sixth, establish an effective incentive and restraint mechanism for compliance management.
In the past, due to the lack of attention to compliance risk management, the incentive and restraint mechanism was relatively lacking, with less praise and less punishment. Under normal circumstances, as long as there are no losses or cases, those who violate the rules often only take measures such as education and rectification within a time limit, and rarely take severe punishment. For those who cause losses or lead to cases, the punishment is not severe enough and the disciplinary effect is limited. Compliance culture requires banks to have a clear responsibility system and accountability system, as well as corresponding incentive and restraint mechanisms, so as to form an atmosphere in which all employees are naturally responsible for their careers and work, which fully embodies the values of banks advocating compliance and punishing violations. First, it is necessary to establish and implement a regular evaluation mechanism for compliance operations and a reporting system for major violations. Major and sudden compliance incidents that should be reported or delayed, lied, concealed or omitted shall be dealt with severely according to the relevant circumstances and the degree of adverse impact, in accordance with relevant state regulations or relevant news. If the responsible person actively reports violations or reduces potential risks, the punishment may be mitigated or exempted as appropriate. The second is to establish a compliance accountability system and implement compliance responsibilities. Those who have done a good job in law-abiding work, or contributed to reporting and resisting illegal acts, should be protected, praised or rewarded; We will increase penalties for violations, increase the cost of violations, and strictly investigate the responsibilities of managers at all levels for the existence or concealment of violations, resulting in financial losses and economic cases. Third, it is necessary to establish a re-supervision system for inspectors. The problems found by managers at all levels, compliance department personnel and supervisors in daily compliance risk management were not found, the punishment was not punished, and no rectification opinions were put forward. Joint liability shall be investigated and severely punished.