금융회사의 효과적 내부통제체제 확립방안 모색- 은행을 중심으로 -

The importance of the internal control system is indisputable. This system was introduced to domestic banks in 2000. The current legal structure of internal control seems to be perfect on its face to be supplemented. However, executives in domestic banks are willing to have an apathetic on internal control. Recently, FSC(Financial Services Commission) and FSS(Financial Supervisory Services) announced the some plans to improve the internal control systems. Among the plans, it is included that a compliance officer may be required to oversee and manage compliance issues within a bank and report directly to the representative director in lieu of the audit committee. In addition, to ensure the compliance officer's independence, the term of office for the compliance officer should be at a minimum of 3 years and compliance officer's role is to be adjusted to reduce their working burden. The plan also contemplates limiting the basis for disqualifying the compliance officer of a bank to more serious sanctions. These proposals was already included and introduced in the proposed Financial Institution Governance Reform Act in 2010. This Act finally is passed in the National Assembly on July this year. While initiatives to reform the existing internal control related regulatory regime are welcome, some proposals and revisions raise some concern and should be considered in detail. To improve the current situation in domestic bank, I would propose some suggestions as follows. First, the existence of internal control system does not, on its own, signal the effective management of risk. Effective and efficient monitoring and review are essential components of the internal control. However, now, compliance officer's working coverage is extremely broad. Compliance officer's role should be adjusted to accomplish their mission and duty. Second, effective training and communication assist in embedding the desired culture and behaviors of compliance culture in the company. To cultivate the training of internal control staff, the company should review their training program whether it is effective and efficient. In addition, the internal control related human resources should be disclosed to market. Third, bank should ensure that its compensation policies consider the employee's consistency of performance, adherence to the internal guidelines rather than just short-term financial performance and results. Most of all, CEO and board of directors are the one who oversees the quality of internal control. Especially, CEO has the responsibility to implement and enforce internal controls with law and regulations. The CEO should involve himself or herself in the entire internal control process. The CEO will need to ensure the board of directors receive sufficient information about the internal control system. To build a company culture, it is important that the internal control systems include measures how the expectations of the board and CEO are to be communicated to employee and what training may be required to meet their expectations. It is noteworthy to comment that the supervisory organization' s single and strict guidance on the procedure by which a company designs and implements its internal control systems would be misguided if it led company to underestimate the importance of culture of internal control. In addition, adequate policies and processes within the financial conglomerate to enable conflicts of interests to be identified and managed should be established and responsibilities and functions concerning internal control, risk management systems and compliance functions in the financial conglomerate should be concretely subscribed.