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.

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