Money laundering: where to start.

Chad has been assessed. From 9 to 27 May 2022, a team from GABAC — the FATF-style regional body covering the CEMAC zone — carried out on site the mutual evaluation of the national framework for combating money laundering and terrorist financing. The report was published in July 2023. It measures two distinct things: technical compliance with the FATF's forty recommendations, and the framework's actual effectiveness.

That distinction is the whole subject. A country — like a company — can have impeccable rules and a framework that produces nothing. It is the most common case, and the most expensive: it gives the feeling of being covered when you are not.

For a bank, a microfinance institution, a professional firm, a company handling flows of funds: the question is not « do we have a procedure? » but « what actually happens when a transaction falls outside the ordinary? » That is the ground of our regulatory compliance expertise.

The order that works

Many organisations start by drafting a manual. That is the opposite of what is needed. A manual written before looking at your own flows describes an organisation that does not exist.

The order that holds is this. First the risk map: who are our customers, our products, our channels, our geographies, and where is the exposure concentrated. This map is not one more document — it is what justifies everything else, and it is the first thing an inspector asks for.

Then customer due diligence. Identify the customer, understand the purpose of the relationship, know who the beneficial owner is — that is, the natural person who ultimately owns or controls. This is where most frameworks stop, because it is the most uncomfortable point to hold in front of an important client.

Only then, the written procedures, transaction monitoring and the suspicious transaction reporting chain. Written last, they describe what exists.

Three signs that a framework is decorative

The first: nobody can say how many suspicious transaction reports were filed last year. The second: the procedure exists, but no front-desk officer has ever read it. The third: the compliance officer reports to the person whose decisions they are supposed to check.

None of the three needs an audit to be established. They are visible in half a day.

What we do with it

We trained the managers of the Banque Commerciale du Chari across four areas, including customer due diligence — the KYC Specialist certification. Training is not an add-on to compliance: in an anti-money-laundering framework, it is the officer at the counter who detects, or nobody detects.

That is also why our training programmes run over time rather than as a single session. A framework is built in this order, it is maintained, and it is checked.

Risk may open a discussion; it is method that must close it. See what that looks like in our assignment at the Banque Commerciale du Chari.