国际合规标准在乌克兰银行本地法律中的扩散模式

Sergii Sheludko
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It is analyzed the Codes of conduct (ethics) and similar documents of systemically important banks of Ukraine. Since the sample was represented by state, foreign and private Ukrainian banks, as a result, not only the key features of the analyzed documents were determined for each institution, but also the common and distinctive within the framework of classification groups were identified. Therefore, state banks focus on avoiding conflicts of interest and responsible use of property, banks with foreign capital – on protecting consumer rights and compliance with financial monitoring requirements, and private domestic banks – on relations with own shareholders and employees' compliance with corporate style. The common feature of the considered acts of local law is the emphasis on relations with customers and competitors, proper handling of confidential information, procedures for cooperation with partners, suppliers and agents, maintaining a high culture of risk management, prevention of any manifestations of corruption, abuse of official position, bribery with special attention to giving and receiving gifts. 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Models of international compliance standards' diffusion into local law of ukrainian banks
. The paper is devoted to the economic and legal study of models of international compliance standards' diffusion into local law of Ukrainian banks. It is used the method of comparative analysis of relevant internal documents of 15 largest institutions to determine the specifics of coverage of certain aspects of compliance. It is identified the key risks of the generalized approach to the adaptation of world practice into applied models for ensuring the compliance of domestic banks. It is provided the main recommendations for mitigating the negative consequences of implementing the specified challenges. It is characterized the organizational and legal features of the introduction of international compliance regulation standards in the practice of the NBU. It is analyzed the Codes of conduct (ethics) and similar documents of systemically important banks of Ukraine. Since the sample was represented by state, foreign and private Ukrainian banks, as a result, not only the key features of the analyzed documents were determined for each institution, but also the common and distinctive within the framework of classification groups were identified. Therefore, state banks focus on avoiding conflicts of interest and responsible use of property, banks with foreign capital – on protecting consumer rights and compliance with financial monitoring requirements, and private domestic banks – on relations with own shareholders and employees' compliance with corporate style. The common feature of the considered acts of local law is the emphasis on relations with customers and competitors, proper handling of confidential information, procedures for cooperation with partners, suppliers and agents, maintaining a high culture of risk management, prevention of any manifestations of corruption, abuse of official position, bribery with special attention to giving and receiving gifts. The obtained results have an applied value due to considering the specified models of international compliance standards' diffusion in the development of internal normative support of banks on compliance issues.
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