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In order to identify the risk of loss of business reputation, it is recommended that the credit institution determine in internal documents:
- internal and external reputational risk factors and how they are identified;
- How to conduct a reputation risk analysis;
- Examine the impact of reputational risk factors on the operations and financial condition of the credit institution;
- customer identification and research program, especially clients with whom the credit institution carries out banking transactions and other high-risk transactions, program of identification and identification of beneficiaries, Know Your Customer.
In order to assess the risk of loss of reputation, it is recommended that the credit institution provide for:
- Reputational Risk Measures based on the factors involved;
- How to assess the level of reputation risk, including on a consolidated basis;
- analysis of the impact of business reputation of affiliates, subsidiaries and affiliated organizations on the level of risk of loss of business reputation of the credit institution;
- analysis of the impact of charitable and social activities of the credit institution on its business reputation;
- Analysis of the impact of the credit institution 's advertising and information policy on business reputation.
When assessing the level of reputation risk, credit institutions can focus on the following indicators:
- change of financial condition of the credit institution (for example, change of structure of assets of the credit institution, their impairment in general or in part of certain groups, change of structure of own funds (capital) of the credit institution);
- increase (decrease) in the number of complaints and claims against the credit institution, including regarding the quality of service to clients and counterparties, observance of business customs;
- negative and positive feedback and reports about a credit institution, its affiliates, subsidiaries and affiliates in the media compared to other credit institutions for a certain period of time;
- the evolution of the share of assets placed as a result of transactions with affiliates, subsidiaries and affiliates in the total amount of assets;
- The credit institution implements risky credit, investment and market policies.
Decrease or occurrence of probability of decrease of liquidity level and timeliness of settlements on behalf of clients and counterparties;
- Identify, within the framework of the internal control system, cases of non-compliance with the requirements "to counter the legalization (laundering) of proceeds of crime and the financing of terrorism," as well as signs of possible involvement of a credit institution or its employees, affiliates, subsidiaries and dependent organizations in the legalization (laundering) of proceeds of crime and the financing of terrorism;
- identification of grounds for believing that conditions are being created to avoid mandatory control procedures provided for by the legislation of the country in order to counteract legalization (laundering) of proceeds of crime and financing of terrorism, as well as to fail to comply with and/or incomplete follow-up to the recommendations of the Central Bank for these purposes;
- Failure to comply with the rules of internal control in order to counter the legalization (laundering) of proceeds of crime and the financing of terrorism, leading to the failure to provide the authorized authority with information on banking transactions and other transactions, which (Including in accordance with recommendations of international and foreign organizations engaged in activities in the field of counteracting legalization (Laundering) proceeds of crime and terrorist financing) are obviously suspicious or may be used to legalize (Laundering) proceeds of crime or financing terrorism or other illegal activities;
- Change of business reputation of affiliates, subsidiaries and affiliated organizations.
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