Compliance Function


Bank Respublika prioritizes lawful, transparent, and responsible financial operations. The Bank's Compliance function is aimed at ensuring adherence to national legislation and international regulatory frameworks, promoting ethics and professional conduct, managing risks, and safeguarding customer trust. Compliance is not merely a regulatory requirement—it is a cornerstone of the organizational culture.

The Compliance function at Bank Respublika is established in accordance with the “Corporate Governance Standards in Banks” issued by the Central Bank of the Republic of Azerbaijan and international compliance frameworks such as those of the Basel Committee. Compliance operations are governed by the Bank’s official “Compliance Policy,” which outlines how compliance and ethical conduct processes are structured across the Bank’s departments. The function serves the following objectives:

  • Ensuring operations comply with local legislation and international standards;
  • Monitoring implementation of internal policies and procedures;
  • Promoting ethical behavior and safeguarding corporate values;
  • Early identification and proactive management of compliance risks;
  • Preserving the Bank’s public reputation and sustaining trustworthy relationships with stakeholders.

Compliance culture is embedded and implemented at all organizational levels within Bank Respublika. This culture:

  • Increases employees’ awareness of legal, regulatory, and ethical risks and encourages a sense of individual responsibility; it promotes consideration of compliance in every decision;
  • Establishes a culture of “doing the right thing” and “anticipating risk” across all levels—not just for management but also for frontline staff;
  • Lays a solid foundation for long-term strategic reliability, transparency in relations with clients and regulators, and sustained protection of corporate reputation;
  • Encourages open communication, anonymous reporting, and a climate of trust to timely detect ethical dilemmas and potential violations;
  • Strengthens compliance culture through systematic training programs, awareness sessions, and leadership support.

This approach positions the Compliance function not just as a control tool but as an element of strategic management and risk culture. Compliance is not limited to regulatory oversight but is also an inseparable part of management and behavioral culture. To foster this culture, regular trainings, awareness initiatives, and communication programs focused on managing ethical risks are conducted.

Ethical Conduct


For Bank Respublika, ethical conduct is more than a set of internal rules—it is a continuous corporate principle based on personal responsibility, customer value, and public trust. The Bank’s “Code of Ethical Conduct” sets forth expected standards and values for all employees, management, and partners. Adherence to the principles of transparency, honesty, and responsibility is not only a legal obligation but also a behavioral norm for all staff.

  • Honesty and Transparency: Employees must act openly and honestly in all activities;
  • Customer Interests: Client rights and trust are top priorities;
  • Confidentiality of Information: Protection of client and bank data is a firm principle;
  • Rejection of Unlawful Influence: Corruption, undue pressure, and conflicts of interest are strictly opposed;
  • Accountability and Transparent Decision-Making: All decisions must be based on ethics and legality.

Prevention of Conflicts of Interest


A conflict of interest arises when an employee’s personal interests potentially or actually contradict the interests of Bank Respublika or its clients. If not properly identified and managed, such situations can undermine objective decision-making, damage the Bank’s reputation, and breach regulatory compliance.

Under its “Conflict of Interest Policy,” the Bank implements the following measures:

  • Disclosure and Transparency Principle: Employees must declare any business interests, additional income sources, close family relations, or other situations that may create a conflict. Disclosure and confirmation mechanisms are regulated within the policy;
  • Objective Relations with Vendors and Suppliers: Any person with a potential conflict is excluded from the selection process. If an employee has a personal relationship with a vendor, it must be declared in advance. Contracts with suppliers include ethical conduct clauses to ensure transparency and integrity;
  • Gift Control and Restrictions: Receiving gifts, entertainment, or any material benefits from clients and partners is strictly prohibited;
  • Recusal from Decision-Making: Employees with a conflict are removed from relevant decision-making processes, with official documentation of the recusal;
  • Ethics Training: All employees receive periodic training on identifying and managing conflicts of interest, with real-life case examples.

Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF)


To protect the stability of the financial system and maintain international confidence, Bank Respublika enforces a robust AML/CTF control and management framework. The Bank operates in line with the laws of the Republic of Azerbaijan, including the “Law on the Prevention of Legalization of Criminally Obtained Property and Financing of Terrorism,” “Targeted Financial Sanctions,” and the AML/CTF regulations of the Central Bank, as well as recommendations from the FATF and Wolfsberg Group.

Implementation of these requirements is ensured through internal regulatory documents, including:

  • AML/CTF Policy
  • Risk Appetite Statement
  • Know Your Customer (KYC) Program
  • Customer Due Diligence (CDD) Procedures
  • Investigation and Reporting Procedures for Suspicious Transactions

Key measures include:

  • Customer Identification: Collection and verification of information about customers and beneficial owners under CDD standards;
  • Risk-Based Approach: Clients and products are assessed by risk level, with enhanced monitoring for high-risk categories. CDD measures vary depending on the customer’s risk classification;
  • Transaction Monitoring: Suspicious activities are automatically analyzed through advanced systems;
  • Internal Policies and Training: Comprehensive AML/CTF policies, procedures, and training programs are in place;
  • Assessment of New Products and Technologies: Every new product or digital solution is evaluated for AML/CTF risks.

International Sanctions


As a trusted participant in the global financial system, Bank Respublika ensures full compliance with international sanctions regimes. The Bank operates under the national laws of Azerbaijan and aligns with decisions and recommendations from the UN, OFAC (U.S. Treasury), the EU, the UK’s HMT, and other international bodies.

The Bank implements a “Sanctions Compliance Program,” which includes:

  • Sanctions List Screening: Real-time automatic screening of customers, beneficial owners, counterparties, and transactions against local and global sanctions lists (including those from the Financial Monitoring Service, OFAC, EU, UN, UK HMT, etc.);
  • Correspondent Banking Relations: In its strategic partnerships with correspondent banks, the Bank prioritizes compliance, transparency, mutual trust, and strong sanctions controls. Cooperation with high-risk parties is avoided;
  • Blocking and Freezing Transactions: Any financial operations involving sanctioned individuals or entities are immediately frozen and investigated. If needed, compliance risk assessments are conducted;
  • Onboarding Due Diligence: Special oversight is applied to clients and countries classified as high risk;
  • Trade Transaction Review: All foreign trade operations, including import and export, are assessed and monitored for sanction compliance;
  • Training and Awareness: Employees across relevant departments receive regular training and participate in experience-sharing sessions focused on real case examples and international guidance.

Anti-Bribery and Anti-Corruption


Bank Respublika adheres to a zero-tolerance approach to bribery and corruption, operating in full compliance with Azerbaijani legislation and international ethical and regulatory standards.

Within its “Anti-Corruption Policy,” the Bank undertakes the following measures:

  • Prohibition of Bribery and Illicit Benefits: Employees and management are strictly prohibited from offering or accepting any material or non-material benefits (gifts, commissions, discounts, etc.) from any person or organization;
  • Gift and Hospitality Policy: Gifts or hospitality can only be accepted with prior approval, in line with procedures defined in the Anti-Corruption Policy. Illegal or unethical actions must be reported immediately;
  • Vendor and Partner Monitoring: Relationships with vendors and service providers must be transparent, fair, and subject to control. Cooperation is discontinued in cases of corruption risks;
  • Fair Recruitment and Career Progression: All HR processes — hiring, appointments, rotation, and promotions — are based on professional competence and objective criteria. Controls against nepotism and informal arrangements are enforced;
  • Awareness and Ethics Training: Regular trainings are held for employees on ethical conduct, legal and reputational risks of corruption, using real-life examples;
  • Compliance, Legal Review, and Investigations: All suspected corruption incidents are investigated. If necessary, disciplinary procedures and referrals to law enforcement are initiated.

Anti-Fraud Measures


Bank Respublika considers fraud prevention one of the key pillars of its internal control, risk management, and corporate ethics framework. The goal is to detect and prevent fraud risks—both internal (from employees and processes) and external (from clients, partners, and suppliers)—in a timely manner and preserve public trust in the financial system.

Under the approved “Anti-Fraud Policy,” the Bank has established the following:

  • Internal Controls and Audit: Multi-level transaction approvals, segregation of duties, and risk-based monitoring are applied. Internal Audit and Compliance units conduct ongoing independent checks;
  • Technological and Physical Security: All IT systems are protected according to data security standards. Real-time monitoring systems identify and analyze potentially fraudulent activities;
  • Candidate Screening: Recruitment processes include assessment of candidates’ reputation, previous conduct, ethical integrity, and financial responsibility, with additional checks for sensitive roles;
  • Protection of Internal Data: Access to financial data is restricted, system logs are maintained, and technical measures are taken to mitigate data leakage risks;
  • Awareness and Training: Training programs based on real scenarios help staff recognize suspicious signs and understand reporting mechanisms;
  • Third-Party Risk Management: Contracts with vendors and contractors include anti-fraud clauses. Compliance conducts prior due diligence and continuous monitoring.