Assessments conducted on the activities exposed to the risk under Legislative Decree 231/01
In 2015 the Internal Audit Function activities, performed on behalf of the Supervisory Body, were related to different areas/processes of the Bank, including the following, which are particularly ‘sensitive’ to Legislative Decree 231/01:
Banca Prossima "Third Value" (platform created by Banca Prossima, that allows individuals and companies to lend money directly, without intermediaries, to "non-profit" projects
Fondo Speciale Ricerca e Sviluppo (Research and Development Special Fund) loans; loans backed by the guarantee of the central fund under Law 662/96
Processes for the detection of suspect transactions under "market abuse"
Customers operating in the lottery, betting, casinos, penny arcades (with a focus on Direzione Regionale Milano and Direzione Regionale Lombardia)
Earthquake in Emilia Romagna and Abruzzo: dedicated public funding and moratorium measures
Anti-money laundering and compliance fulfilments on various foreign branches and Group companies, also outside EEC
Anti-Money Laundering Service: effectiveness of "second level" checks in the Intesa Sanpaolo Group
Compliance checks on purchasing of goods and services; monitoring of ICT purchases; relevant processes in outsourcing and externalization of important operational functions
In 2015, the Compliance Department conducted assurance activities on the areas of activities most exposed to the risk of committing the so-called “predicate” offences pursuant to Decree 231/01. In particular:
the sensitive area of offences against the Public Administration, with specific controls on the management of support granted to major events (EXPO 2015) and management of indirect taxes as withholding agent within current accounts
the area concerning administrative crimes and offences ascribable to market abuse, with ongoing monitoring on sensitive transactions
the sensitive area concerning measures against terrorism and money laundering, developing specific trend monitoring indicators.