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Crédit Agricole S.A.Update of the 2011 registration document - A03project is to combine the regulatory aspects and relational commitments made by the Regional Banks in theroll-out of the Group project.At the same time, the Group Compliance Department has taken steps to enhance application of the MiFIDDirective concerning updating customer qualification and protecting fragile persons investing in the financialmarkets.In the area of financial security, the persistence of global political and economic crises necessitates thepermanent upgrading of procedures within Group entities, particularly in terms of embargos and freezing ofassets. In France, the Group Compliance Department took part in industry works on the implementation ofan identification form for beneficial owners and a formalised specific procedure, in accordance with thedemands of the EU’s Third Money Laundering Directive, which will be rolled out within Group entities duringthe autumn of 2012. Concerning tools, deployment in ongoing of the tool for detecting unusual transactionswithin international retail banking subsidiaries (Albania, Romania, Bulgaria), as well as for the filtering tool forSwift payment flows (regulations concerning embargos and freezing of assets).As regards fraud prevention, the renewal of the questionnaire on the roll-out of procedures in all Groupentities helped to enhance steering by the Compliance Department. This system is now in place at allentities. Efforts will continue in the second half of the year in terms of the management and roll-out ofsteering tools and tools to fight identity and document fraud. Work is also underway to temporarily extend thescope of existing detection tools in respect of fighting money laundering. In addition, a benchmark of markettools specialising in fraud prevention is in the process of being set up.The Group has also pursued a variety of training initiatives, including the roll-out of the new version of theCompliance e-learning module and the creation of a two-day training programme dedicated to fraudprevention.Lastly, the Group’s relevant business lines are engaged in an active regulatory watch of currentdevelopments in Europe and the United States. In particular, the plan for complying with FATCA regulationsis steered by the Group Compliance Department.PERIODIC CONTROLSGroup Control and Audit has the exclusive responsibility of carrying out periodical controls of the CréditAgricole Group through its audits and through oversight of the Crédit Agricole S.A. Group Control and Auditfunction, which reports to it.During the first half of 2012, Group Control and Audit conducted on- and off-site audits of a number ofentities and units, and namely on the means of calculating economic capital (Basel II - Pillar 2), corporategovernance and management of payment methods, filtering of international payment flows, ExchangeTraded Funds (ETFs), the creditor insurance subsidiary CACI, foreign subsidiaries of which Credit AgricoleSerbija, Cariparma (control and credit risk) and Centea (following its acquisition by Crédit Agricole deBelgique), the system for managing liquidity and loans eligible for refinancing at the Regional Banks,workplace safety and critical infrastructures at SILCA, and a number of other financial, regulatory andtechnological issues.Through the relevant Group subsidiaries’ Internal Control Committees, which are composed ofrepresentatives of each entity’s senior management and internal audit department as well as theirPermanent Controls and Compliance Officer, in overseeing the control and audit function, Group Control andAudit ascertains that audit plans are successfully carried out, that risks are properly managed, and, moregenerally, that each entity’s internal control systems are adequate.Page 107 sur 237