Regulatory Alerts2024-09-18
Reporting of Embezzlement by Employees and Officeholders
The Supervisor of Banks mandates that banking corporations report reasonable suspicions of employee or officeholder embezzlement to the internal auditor and the Supervisor. This directive establishes specific reporting thresholds, requiring preliminary notification within seven days for incidents exceeding NIS 20,000 or US$ 20,000, and immediate reporting for substantial embezzlement cases. It further defines substantial incidents based on quantitative and qualitative criteria, such as amounts exceeding 2 percent of capital or involvement of senior personnel, and requires detailed supplementary reports outlining internal control defects and remedial actions.
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