7.4.1. Brazil: IT systems for ongoing monitoring and engagement

224. The Central Bank of Brazil (BCB) applies a methodology called Conduct Continuous Monitoring (ACC) for the highest risk financial institutions which means that at least one supervisor is in charge of continuously assessing the corporate governance, risk management and compliance of each of these institutions. The ACC methodology provides the BCB with an updated risks profile for each of these financial institutions. For less risky banks and non-banking institutions, the BCB developed a methodology and an IT system for carrying out off-site inspections, called APSSiscom (BCB SupTech). With this technology, remote compliance inspections (ICR) assess AML / CFT policies, procedures and internal controls. All interactions with the institutions, as well as requesting and analysing documents and information, are carried out through APS-Siscom. If any breach is detected during the ICR, the institution is notified and requested to present an action plan, which is approved and followed by the supervisor through APS-Siscom. Depending on the ICR outcomes, the supervisor may propose remedial actions or sanctions, including termination of the business.

7.4.2. Russia: RegTech solution to provide ongoing feedback to the private sector

225. The Russian FIU, Rosfinmonitoring, implements a RegTech solution it calls 'Personal Account' to provide feedback to entities on STRs filed but also the specific risks the entity is exposed to, based on a range of information including compliance with AML/CFT requirements - see the diagram below.