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On how to realize the effective compliance management of Agricultural Development Bank
At present, while actively expanding business and strengthening basic management, Agricultural Development Bank is facing increasingly complex risk situation and management requirements. Compliance management will inevitably become a fundamental and long-term measure to prevent and control operational risks and safeguard the safety of assets and teams. Starting with the problems faced by the compliance management of Agricultural Development Bank, this paper explores the effective ways to realize compliance management, and on this basis, puts forward some suggestions to further promote compliance management. I. Problems and Challenges Faced by Compliance Management (I) Weak awareness of compliance and insufficient initiative to consciously safeguard compliance. Due to misunderstanding and deviation of ideas, they pay less attention to compliance management, pay more attention to the completion of profit targets and business performance assessment, pay more attention to business development rather than compliance management and risk prevention and control, and pay more attention to the struggle for financial resources rather than the supervision of rational use of resources. Some operators are not fully aware of compliance risks, the serious consequences and reputation risks that may be caused by illegal operations, the prevalence of acquaintance culture, the substitution of trust for management, the substitution of habit for system and the substitution of respect for discipline, the existence of luck, the lack of awareness of voluntarily observing laws and regulations, and the lack of vigilance and sensitivity to prevent compliance risks. (2) Compliance management implementation is not in place. Most of the problems exposed through various external inspections in recent years are rules to follow, orders to fail, and inadequate system implementation. For example, the pre-loan investigation is not due diligence, the review is not strict, the loan purpose is not verified, the loan purpose is not tracked, and problems are not handled when found. Another manifestation of insufficient execution is that for the newly implemented system methods and regulations, due to the long chain of system transmission, operators at different levels and departments have limitations and deviations in understanding the same system, resulting in insufficient or delayed execution of the system. For example, after paperless loans and illegal points are fully implemented, some banks' system audits become a mere formality, and some banks still operate on their behalf. (C) The internal control mechanism and management methods need to be strengthened. As far as the internal control mechanism is concerned, the implementation of the current supervision system is not perfect. On the one hand, the role of the supervision and management platform has not been effectively played, and the guidance, monitoring and management of the accounting department, the loan department, the general office and other departments are still lacking, which needs to be studied as soon as possible. On the other hand, in the existing system, the supervision duties of business managers, class teachers, discipline inspection and supervision have not been effectively exerted, and there are problems such as poor performance of their duties, and the effectiveness of implementation needs to be improved. In terms of management means, information construction is accelerating, business processing is gradually systematized and networked, and the content and requirements of compliance management are increasing. However, the current management methods are relatively abandoned, limited to written regulations, manual implementation and post-event inspection. Due to the skill level and moral quality of personnel, supervision and management are not timely and effective, and compliance operating standards are not quantified enough, so it is difficult to analyze potential risks in time, realize real-time risk prevention and control in the whole process, and expand the depth and breadth of supervision and management. (D) The incentive, assessment and restraint mechanisms are not perfect. First, the incentive assessment is not in place. The current business performance appraisal system has greatly promoted the enthusiasm of business development, but it lacks quantitative assessment of compliance management, so that it unilaterally pursues business development characterized by scale expansion. When there is a conflict between business development goals and compliance management, there will be a phenomenon of pursuing business development while diluting legal compliance management and emphasizing short-term interests rather than long-term development. Second, the responsibility restraint mechanism is not perfect. At present, there are problems such as unclear job responsibilities, inadequate implementation of responsibilities and inadequate supervision and inspection. Due to the shortage of personnel and other factors, the actual effect of centralized inspection is not great, the investigation and punishment of compliance management problems is not enough, and the accountability is not strict. Two. Effective ways to practice compliance management There is no shortcut to achieve compliance management. We must take Scientific Outlook on Development as the guide, adhere to the business philosophy of "compliance management and strict management", adhere to the principle of "people-oriented, combining punishment with prevention and comprehensive management", and strive to implement compliance culture construction around the theme of "active compliance and comprehensive compliance". (1) System construction is the basis of compliance management. Compliance management and steady management must constantly strengthen the construction of internal rules and regulations as an important basic work. Take all rules and regulations as a "firewall" to prevent risks, let all kinds of rights check and balance each other, keep power in the cage of the system, and form a long-term mechanism of managing power, doing things according to the system and managing people by the system. First, on the basis of revising and refining rules and regulations, improve the system execution and the accuracy of system execution. On the one hand, to sort out, refine and revise the rules and regulations formulated by the superior bank within the scope of authorization, so as to cover all business lines, all kinds of products and services, all links and posts, and improve the compliance management level; On the other hand, according to the changes of external environment, laws and regulations, business risks, superior requirements and other factors, we should revise and improve our own rules and regulations and keep pace with the times. The second is to standardize business processes. Further strengthen the reengineering of compliance management process, establish a standardized mechanism combining grading with compartmentalization, and improve the compliance management framework, supervision and assessment methods. , so that all aspects of business management are strictly constrained, and the process control of compliance management is realized. The third is to establish a system coordination mechanism to ensure that relevant systems and management methods are consistent with compliance management, and to ensure the effective connection between various systems. (2) Implementation is the key to compliance management. No matter how good the system is, the key is to implement it well. Otherwise, it will become a mere formality and exist in name only. Therefore, it is necessary to continuously strengthen the implementation of the system. In this regard, leading cadres and managers should set an example and achieve effective and benign interaction in the construction of compliance culture. On the one hand, it is necessary to strengthen the supervision and inspection of the implementation of the system, establish the corresponding accountability mechanism, urge employees to improve the awareness of system implementation, and enhance the implementation of the system. On the other hand, it is necessary to establish an evaluation mechanism after the implementation of the system, regularly track and evaluate the implementation of the introduced system, analyze the ineffective implementation of the system, find out the reasons, investigate the responsibilities, and constantly improve. (3) Supervision and inspection is the guarantee of compliance management. Supervision and inspection is an important guarantee to test the effectiveness of compliance management. In the process of compliance management, we should always look in the mirror, get dressed, take a bath and treat diseases. It is necessary to carry out supervision and inspection on a regular basis, and adopt a combination of line inspection, cross inspection and overall shift inspection to prevent micro-duration, find loopholes and weak links as early as possible, and continuously improve the level of compliance management. First, improve the supervision mechanism and further strengthen the construction of "three lines of defense" for compliance risk management. Constantly strengthen the construction of internal control mechanism, build various defense lines of risk management, form a risk prevention and control system with effective connection of points, lines and areas, effectively eliminate the "blank points" and "blind areas" of compliance risk management, and ensure that violations are investigated and corrected. The second is to improve the supervision and restraint mechanism, strengthen the construction of the accounting "trinity" supervision system, and improve the punishment and incentive mechanism, which will have a deterrent effect on hell to pay, the person responsible for serious violations of discipline, and achieve the effect of learning from the past. At the same time, a reward and encouragement mechanism should be established to reflect the real role of rewarding the superior and punishing the inferior. (D) Team building is the basis of compliance management. Human risk is the biggest risk. Therefore, we must attach great importance to and strengthen the construction of the staff. The first is to cultivate a proactive compliance culture. Strengthen the political and ideological education of employees, strengthen the concept of system, do things strictly according to the rules, and form a good compliance culture. The second is to do a good job in learning and training. Adhere to capacity building as the core, pay attention to strengthening the pertinence, systematicness and diversity of employee education and training, and truly be familiar with the business and abide by the rules and regulations. Third, vigorously carry out practical activities on the theme of compliance management, organize business skill competitions across the Bank, and vigorously promote experience and practices such as morning meeting system, loan evaluation system and teller culture construction, so as to enhance compliance management execution and employee cohesion. Three. Suggestions on further promoting compliance management (1) Strengthen awareness and enhance the initiative of compliance management. Effective measures must be taken to make the concept and consciousness of compliance penetrate into the blood of all employees, penetrate into every post and every business operation link, so that all employees can abide by laws, rules and standards when carrying out compliance management, and everyone can abide by them everywhere, so that the concept of "prevention and control first, steady operation" is deeply rooted in the hearts of the people and the initiative of compliance management is enhanced. At the same time, compliance should start from the top, clarify the responsibility of compliance management of the top, give full play to the demonstration and guidance role of leading cadres and managers, establish a scientific management concept, and create a good atmosphere of positive compliance from top to bottom. (2) Innovative mechanisms to enhance the synergy of compliance management. First, gradually establish a long-term mechanism for effective compliance management, refine and improve the basic systems conducive to compliance management based on risk prevention and control, including compliance early warning mechanism, compliance performance appraisal system and compliance accountability system. The second is to strengthen the joint efforts of compliance management. Adhere to the concept of "great compliance", give play to the role of the internal supervision and management committee, establish a compliance management cooperation mechanism covering planning, customers, credit, risk, accounting, internal audit, human resources and other departments, clarify the compliance management tasks of all departments, and strengthen division of labor and cooperation and information communication. The third is to strengthen compliance management. In order to meet the requirements of "great compliance" management, we will gradually increase the number of legal compliance professionals in tier-two branches and county-level branches, and equip them with part-time compliance management personnel to provide guidance and consulting services for compliance management, and form an all-round compliance management mechanism of "self-control" by employees, "mutual control" by post departments and "monitoring" by line level. (3) Refined operation to improve the quality of compliance management. In order to cope with market competition and strict external supervision and realize scientific and effective development, we must change the management mode from extensive management to refined management, do more refined work and promote the realization of compliance management objectives. First, establish the concept of "refined management", take refined management, Excellence and pursuit of Excellence as a spirit and a concept, and promote compliance and development with refined management. Second, strengthening basic management and implementing basic system is always the top priority of refined management. Focus on promoting the refined management of credit and accounting, and gradually realize the goal of "clear job responsibilities, comprehensive system coverage, standardized business operation, high-quality workflow and strict risk prevention and control". It is necessary to establish a system of post-system evaluation and leak detection and update, and make appropriate improvements and updates to business policies, behavior manuals and operating procedures in view of the problems found, so as to ensure the effectiveness of the system and adapt to the new needs of business development. Third, in terms of compliance objects, we should not only strengthen the control of credit, accounting and cashier business, but also strengthen the mutual restriction between the front and back offices of the business to ensure that compliance management can cover all levels and aspects of business activities. (4) Renew ideas and promote the construction of compliance management culture. Compliance management is an important part of corporate culture. Business is a leaf, management is a branch, system is a stem, and culture is the root. All enterprises should be prosperous and fruitful. The most important thing is to solve the problem of "root" and cultivate an excellent compliance culture, so that the compliance culture can instill soul and thoughts into the branches and leaves through subtle influence, and ideologically form a realm in which everyone actively abides by the law and is unwilling to violate the rules. Compliance culture is divided into three levels: the best policy is to attack the heart and integrate compliance culture into faith; China's strategy is to integrate compliance culture into business development; Formulate rules and regulations to integrate compliance culture into compliance and discipline. To cultivate a compliance culture between faith and law and discipline, though flexible, it has a bottom line, consciously sublimate moral sentiments, abide by the bottom line of law and discipline, create a positive cultural atmosphere, advocate the sense of responsibility of "everyone is responsible for compliance", the value concept of "compliance creates value" and the warning consciousness of "violation will be investigated", and root the compliance culture in the hearts of all employees and become the code of conduct that all employees consciously abide by. (Contributed by Chang Shaoxiong, Xianyang Branch of China Agricultural Development Bank)