BBVA Compass maintains and follows stringent compliance policies, and as a member of the BBVA Group, has access to the Group’s risk management practices and adopts risk management as one of its main pillars. Following is information on our Bank Secrecy Act (BSA) compliance and training, our Anti-money Laundering protocols and procedures, as well as a description of our presence in an offshore financial center.
Risk Management at BBVA Compass Risk and risk management are inherent aspects of the banking industry. Identifying, measuring and managing risk in a proactive and forward-looking manner are critical to the effectiveness of BBVA Compass’ Risk Management program. Risk Management at BBVA Compass deals with risks and opportunities affecting value creation or preservation, defined as: The process implemented by the board of directors, management and other personnel across the enterprise that is designed to identify potential events that may impact the entity, manage identified risks within established risk appetites and tolerances, and provide reasonable assurance regarding the achievement of entity objectives — both strategic and tactical. The company governs this process through the Enterprise Risk Management Program framework. Utilizing BBVA Group standards as well as U.S. Financial Industry standards, the bank has formalized its Enterprise Risk Management Program with the following ongoing objectives: • Optimize and manage risk across the enterprise tied to strategic initiatives and business plans. • Define the risk appetite of the bank and establish financial and non-financial risk tolerances and limits to protect the safety and soundness, compliance, and reputation of the bank. • Proactively measure and manage each defined risk. • Ensure that proper risk management of the defined risks is integrated with the strategic direction of the bank. • Ensure that organizational goals are clearly defined and aligned. • Establish policies, programs and processes to identify, measure, monitor and control risks. • Integrate and link the Internal Capital Adequacy Assessment Process with the Strategic Planning Process, comprehensive risk assessments and thoughtful stress test scenarios. • Establish comprehensive and targeted Management Information and Reporting concerning the key risk indicators targeting all risks, approved exposure limits and tolerances, and risk appetite. • Promote strong risk governance and oversight through focused organizational alignment of management and board committees. • Ensure that established processes are operating as designed through the use of audit controls and internal examinations. • Promote an effective risk management and control culture.
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By effectively managing risk, BBVA Compass can meet the needs of customers, employees, shareholders and the communities we serve.
Bank Secrecy Act Compliance BBVA Compass maintains comprehensive policies and procedures to comply with applicable United States laws and regulations under the Bank Secrecy Act (BSA), the USA PATRIOT Act, and laws and regulations administered by the U.S. Office of Foreign Assets Control. BBVA Compass has taken the following steps to ensure transparency and compliance: Currency Transaction Reports (CTRs): CTRs are made to the U.S. Treasury Department for cash transactions of more than $10,000 in any business day. Suspicious Activity Reports (SARs): SARs are reported to the Financial Crimes Enforcement Network unit of the U.S. Treasury Department. Suspicious activities include any transaction involving or aggregating $5,000 or more in funds or other assets if the bank knows or has reason to believe that the transaction involves funds derived from illegal activities or is intended to hide illegal-source funds to evade any law, including any currency transaction reporting requirement; the transaction is designed to evade any BSA regulation; or the transaction is atypical for the customer, or has no apparent business or lawful purpose, and the bank cannot reach a reasonable explanation for the transaction after examining the available facts. Monetary Instrument Records: The bank keeps records of certain information required by the BSA with respect to sales of any official check, money order, traveler’s check or bank draft involving currency from $3,000 to $10,000. Other Recordkeeping: Specific recordkeeping requirements apply to taxpayer identification numbers, deposit accounts, electronic funds transfers, extensions of credit, and transfers of funds outside the United States. These records are maintained for at least five years.
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