Report on the Description of the National Settlement Depository Controls, Suitability of Controls Design and Operating Effectiveness,
12 October, 2015
22
Objective 1. Controls provide reasonable assurance that accounts are set up and administered in accordance with complete and
authorized client agreements and applicable regulations
Ref # Control procedure
Testing performed
Results of tests
1.1
Client submitted documents are reviewed by the Legal, Security,
Financial Monitoring, Client Relations and Internal Control
departments.
If no exceptions are identified then the account opening order is
authorized by the director of the Client Relations department and
the contract with the client is signed by both parties.
If exceptions are identified then the documents are returned to the
client and the contract is not signed.
For a sample of signed contracts re-performed the review
procedures and ensured no exceptions were present that
would have prevented the contract from being signed and
account opening order from being authorized.
No exceptions noted
1.2
Master data from client questionnaires is entered or changed in
Alameda (for primary questionnaire) and KBD (for secondary
questionnaire) manually by the client division and verification is
performed by controller.
If no exceptions are identified then the client questionnaires are
signed and master data is authorized in the system only after
verification by controller.
If exceptions are identified then the master data is returned to be
re-entered.
For a sample of signed client questionnaires re-performed
the verification procedures and ensured no exceptions were
present that would have prevented the client questionnaire
from being signed and master data from being authorized.
No exceptions noted
1.3
Unique account numbers are automatically generated by Alameda
(for depo accounts) and ASER (for bank and trading accounts)
based on the master-data, entered by responsible
division
,
according to 385-P instruction.
Observed the account opening process in Alameda and ASER
and noted the automatic generation of unique account
numbers.
No exceptions noted
1.4
Opened client accounts and package of subsequent documents
(tax letter, client letter, report for accounting department etc.) are
verified by controller.
For a sample of opened accounts re-performed the review
procedures and ensured no exceptions were present that
would have prevented the client accounts from being opened
and subsequent documents from being verified.
No exceptions noted
