2019-12-20

This presentation is a professional legal analysis of the internal control of banking system, by conducting a legal assessment of the NBU Board of Directors resolution “On approval of the Regulation on the organization of risk management system in banks of Ukraine and banking groups” No. 64 and “On approval of the Regulation on the organization of internal control system in banks of Ukraine and banking groups ” № 88, in their organic interaction.

“Internal control system” is not only “information about the same” shortcomings “when unloading ATMs” or “analysis of justifications for choosing a taxi service branches.” Excessive primitivization of the internal control system ultimately only harms the profitability of banking business processes.

In our opinion, the implementation of the requirements for the organization of the internal control system should be carried out on a principle “from general to partial”. And to ensure the unconditional implementation of each of the normative requirements stipulated by the NBU Board Regulations No. 64 and No. 88.

We hope the presentation will help us better understand the extensive and varied internal control system currently required by the regulator for banking in Ukraine.

For your convenience, we have created a roadmap for implementing the Regulation on the Organization of Internal Control in Banks of Ukraine.

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