COMPLIANCE AT MOSCOW EXCHANGE

 
 

As a modern high-tech company and an important part of the financial market infrastructure, Moscow Exchange is constantly faced with new challenges, and the way they are solved shapes the future of many individuals and organisations connected to the financial sphere.

Understanding its responsibility and role in developing a culture of trust in the financial market, Moscow Exchange adheres to best Compliance practices and high standards of business ethics and continuously develops compliance rules to meet regulatory requirements and mitigate potential risks. For these purposes Moscow Exchange covers the wide range of compliance topics including the following areas:

  • Compliance with licensing requirements\Internal Control Service;
  • Compliance with economic restrictions;
  • Managing conflicts of interest;
  • Anti-bribery & corruption;
  • AML/CFT/Non-proliferation of WMD (weapons of mass destruction);
  • FATCA, CRS;
  • Insider trading and market manipulation compliance.

ANTI-CORRUPTION

Moscow Exchange is a signatory to the Anti-Corruption Charter of Russian Business and adheres to the principle of zero tolerance of corruption in any form or manifestation. If you identify corruption risk while interacting with Moscow Exchange or if you find non-compliance with the Moscow Exchange anti-corruption policy, you may contact the Compliance Hotline.

COMPLIANCE HOTLINE

The Moscow Exchange Compliance Hotline is an information channel designed for clients and business partners of Moscow Exchange, which accepts messages regarding the Code of Professional Ethics, the Code of Conduct for Moscow Exchange Trading Members, conflicts of interest, corruption risks and unfair practices.

A separate whistleblowing channel is available to Moscow Exchange employees, providing not only for anonymous reporting, but also for receiving an anonymous response. The link to the whistleblowing channel is publicly available to employees on the main page of the corporate portal.

INSIDER TRADING AND MARKET MANIPULATION COMPLIANCE

Moscow Exchange has developed and enforced measures to prevent, detect and suppress misuse of insider information and/or market manipulation, including the availability of internal documents, designating responsible persons and ensuring compliance with internal control rules for preventing, detecting and suppressing misuse of insider information and/or market manipulation.

FINANCIAL MONITORING

In order to combat money laundering, terrorist financing and the financing of proliferation, Moscow Exchange has developed and implemented an internal control system on AML/CFT/Non-proliferation of WMD.

COMPLIANCE WITH ECONOMIC RESTRICTIONS

Considering the specifics of the business activity and the responsibility Moscow Exchange bears as the infrastructure of the market, a necessary condition is the mitigation of the multiple potential risks inherent in this type of activity, including sanctions risk and the reputational risk as well.

For these purposes, Moscow Exchange carries out KYC process for customers and counterparties identification, analyzes products and services offered to its clients, monitors deals and transactions to prevent violations of applicable sanctions legislation or the realization of reputational risk.

FATCA/CRS

Moscow Exchange was registered with the US Internal Revenue Service (IRS) as a Participating Financial Institution not covered by an IGA. Moscow Exchange has been assigned a unique identification number (GIIN): XNBBND.00005.ME.643. IRS W-8BEN-E form.

The Common Reporting Standard (CRS) is the international equivalent of FATCA, aimed at increasing tax transparency and preventing global tax evasion. The Russian Federation confirmed its participation in CRS in May 2016. Russian financial market organisations are required to identify clients that are tax residents of foreign countries (territories) and submit data on such clients and their accounts to the Russian tax authorities.

COMPLIANCE FOR THE MARKET

Moscow Exchange is developing compliance technology to help market participants see their clients and financial instruments in terms of Moscow Exchange expertise, and to improve the quality of regulatory compliance and risk assessment. For more details, please refer to the recording of the conference "Compliance: Key Trends 2021" (Session 4).

Moscow Exchange facilitates the creation and promotion of best compliance practices in the market. In 2021, at the joint initiative of the Bank of Russia, Self-regulatory organizations, Moscow Exchange Group as well as trading and clearing members, a Code of Conduct was created, as well as a way to join the Code and discuss related issues with all the participants.