COMPLIANCE POLICY OF COMMERCIAL BANKS AS PART OF THE BANKING CONTROL SYSTEM

The purpose of the article is to study approaches to the organization of a modern compliance-based banking control system and systematize compliance policy in accordance with the recommendations of the Basel Committee on Banking Supervision and international standards. The research methodology is based on the use of methods of systematization and generalization of scientific approaches to understanding compliance in general and banking compliance policies. The article discusses current issues of compliance development as part of a comprehensive banking control system in Russian banks. Identified approaches to compliance regulation and the specifics of its organization in banking institutions. Presented the structure of the bank's compliance system based on three lines of defense. Analyzed and systematized compliance policies in accordance with the recommendations of the Basel Committee on Banking Supervision. Investigated the specifics of the application of the main types of compliance policies in banking institutions. Revealed that one of the most important areas of compliance in banks is the development and implementation of a code of corporate ethics. Found that one of the most effective compliance policies is the Know Your Customer policy, which allows us to obtain information about customers and the sources of their funds to identify possible criminal intentions. Identified the key principles of the conflict of interest prevention policy. Revealed that the determination of the suspicion of financial transactions or activities of the bank is carried out on the basis of the indicators of risks related to money laundering developed by the Bank of Russia in the context of: the client's activities or behavior, the client's financial transactions, types of products or services. Identified the advantages of implementing a compliance policy for banks, their owners and customers, as well as identified the threats of non-compliance of internal banking operations with compliance policies for a banking institution.