Compliance
HIGHLY COMMITTED IN EVERY ASPECT
BANK OF AFRICA is inherently committed to
complying with laws and regulations and has
extremely high standards when it comes to
compliance. Its entire operations are governed
by a robust compliance policy which ensures
that financial and banking industry regulations
are strictly complied with.
The compliance policy extends to each of
the Group’s subsidiaries by way of a genuine
compliance culture that governs the behaviour
of the Group entire staff at all times. Group
Compliance, which is closely linked to risk
management, plays a key role in ensuring
that all stakeholders, particularly BANK OF
AFRICA’s customers, are fully protected.
COMPLIANCE – A STRATEGIC ROLE
In 2019, BANK OF AFRICA finalised a
range of policies enabling international and
domestic subsidiaries to adopt the Compliance
system. As part of the Group’s convergence
programme, a number of solutions were
introduced during implementation that are
likely to enhance the systems that are already
in place. The Group also pursued efforts
at extending a Compliance culture to all
subsidiaries.
In addition, the Group continued to play its
part in combating money laundering and
terrorist financing, as well as complying with
FATCA legislation and maintaining high
standards of ethics and professional conduct.
Against such a backdrop, the Bank fostered
ties with both internal and external partners
– Bank Al-Maghrib, the UTRF, the AMMC,
the CNDP, the IRS (United States), foreign
banking correspondents as well as its network
of branches and business centres.
Lastly, BANK OF AFRICA initiated a number
of cornerstone projects in response to
regulatory requirements relating to AML/
CFT (anti-money laundering). These projects
and tools are designed to enhance Know Your
Customer procedures, introduce a control
strategy and undertake risk assessment.
COMPLIANCE INCORPORATED AT GROUP LEVEL
In 2019, in accordance with the Convergence project, BANK OF AFRICA continued to roll out Compliance across the Group through a number of initiatives and projects.
Roll out completed at subsidiary level
A significant number of subsidiaries
implemented the Group Compliance system in
2019. As a result, every European subsidiary,
100% of BOA entities including BCB -Bujumbura
as well Salafin in Morocco have now adopted the
Group’s Compliance system. BANK OF AFRICA
also shared Group standards with BANK OF
AFRICA Shanghai and provided assistance to
European subsidiaries undergoing audits by
local regulatory authorities.
The Compliance Community seminar was held
for the third consecutive year in March 2019.
This event aims to foster a culture of dialogue
and encourage information-sharing among the
Group’s subsidiaries.
Lastly, in accordance with the new regulations
introduced in 2019 and in compliance with the
auditors’ recommendations, BANK OF AFRICA
will initiate a far-reaching project to update
existing standards and processes. This project
will span 2020 and 2021.
Post-roll out assistance
BANK OF AFRICA’s Group Compliance project will now transition to the post-roll out phase by identifying the actions needed to enable each subsidiary to comply. In particular, this involves upgrading the body of standards at subsidiaries within the WAEMU region, enhancing the screening system for customers and transactions and adopting a new risk-based approach within screening systems at European subsidiaries. Lastly, subsidiaries are also being called upon to satisfy FATCA requirements and set up an antibribery management corruption system.
Other corrective actions have been implemented
by subsidiaries to resolve the technical
malfunctions of the screening and profiling systems
caused by the introduction of a number of new
IT projects at BOA Group (Banking, new Banking
Accounting Plan).
Lastly, Group Compliance has made its subsidiaries
aware of the need to resize their Compliance teams
to ensure that the newly implemented systems are
efficient and to improve the processing rates for
profiling alerts.
Assistance for audited subsidiaries
Subsidiaries frequently undergo audit
inspections by their regulatory authorities. 19
entities or 63% of the Group’s subsidiaries
have been audited over the past three years. It
should be noted that these audit inspections
did not result in any sanction by the regulatory
authorities.
In response to these audits, Group Compliance
has set up a support system for its subsidiaries.
This system is intended to assist subsidiaries
by providing training to staff working in the
Compliance function, producing deliverables,
reviewing of systems and solutions and
monitoring corrective action.
In addition, Group Compliance continued to
provide assistance to subsidiaries by helping
them with their post-audit remediation plan.