Governance & Compliance

Earning and retaining the confidence and trust of our stakeholders.

Kush Bank appreciates that good corporate governance is fundamental to earning and retaining the confidence and trust of its stakeholders.

A governance and compliance policy provides the structure through which the bank sets its objectives and the means to attaining those objectives.

Governance Structure

Shareholders Engagement

Shareholders Meeting

Shareholders meetings are duly convened annually and held in line with the Kush Bank Articles of Association and the 2012 Banking Act of the Bank of South Sudan and other existing statutory and regulatory regimes. The meetings allow open deliberation on issues affecting the strategic direction of the bank.

Extraordinary General Meeting

An Extraordinary General Meeting may also be convened at the request of the board or shareholders with representatives of Bank of South Sudan to witness, but not allowed to vote.

Senior Management

Appointed by the bank’s board of directors, the senior management team of Kush Bank is responsible for the management and execution of the bank activities, as per policies approved by the board of directors.

The senior management team members conduct their activities and hold Monthly Executive Meetings to review the performance and activities of the bank. The members of each committee comprise of heads of operations, business development, risk & compliance and Support Services.

Board of Directors

The board has the overall responsibility for setting the strategic direction of the bank and the oversight of senior management.

The board meets quarterly to conduct their activities through general board meetings and three different committees:

  • Business Development Committee
  • Finance & Administration Committee
  • Audit & Risk Committee

The board of Kush Bank Plc consists of persons of diverse discipline and skills, chosen based on professional backgrounds and business expertise, integrity, and knowledge of the bank business.

The chairman of the bank is a non-executive director. He/She does not participate in day to day running of the business.

The chief executive officer is responsible for the day to day running of the bank and oversees the bank structure, assisted by the senior management team.


In line with the Banking Act 2012 and Board of Directors’ strategic directives, the head of compliance has been tasked with a bank-wide discretionary power over AML/CFT (Anti-Money Laundering – Combating the Financing of Terrorism) related matters. This senior team member also ensures that the bank complies with applicable AML/CFT and allied regulations and obligations derived from existing laws and regulations without exception. Kush Bank aspires to have zero tolerance on non-compliance. As such, the Kush Bank has designed and implemented an anti-money laundering program to identify, assess, monitor and manage risks related to money laundering, terrorist financing, financial crimes, etc. Regularly, the bank will examine its AML/CFT strategies, goals and objectives and maintain an acceptable program for its business that reflects best-in-class practices for a reputable financial services provider.

The bank AML/CFT framework encompasses:

  • Board of directors’ responsibilities which include setting up and approving AML/CFT and Compliance Framework of the bank while management is responsible for operationalizing the framework.
  • Customer identification & verification program, Financial Crime Surveillance and Reporting Obligation.
A more detailed policy and working document on the governance and compliance of Kush Bank is available as part of the company documents.