Alain UCARI manages the Pictet Group’s banking arm, which was recently established in Monaco. He is also Secretary of the Monaco Association of Financial Activities (AMAF) and Chairman of the AMAF’s Anti-Money Laundering and Professional Certification Committees. We asked him some questions about his work.
What is your role within the Anti-Money Laundering and Terrorist Financing (AML-TF) Liaison Committee?
I represent AMAF. The AML-TF liaison committee was created by Sovereign Ordinance, and since August 2018 its composition and functioning have been governed by articles 49 and 50 of this Ordinance. It aims to ensure a two-way exchange of information between the Monaco government departments affected by AML-TF, and professionals governed by amended law 1,362: lawyers, bailiffs, retailers, estate agents, bankers, etc. The Committee meetings allow us to discuss mutual interests in order to improve the efficacy of AML systems put in place by these professionals.
The Committee is coordinated by SICCFIN (the Financial Circuits Information and Control Unit). It holds regular and significant meetings, discussing FATF (Financial Action Task Force) public declarations, draft legislation, the implementation of information systems, and money laundering schemes which reflect criminal trends observed internationally and which are seen as a concern. Technological crime is a significant risk. It has an effect on our financial industry’s reputation.
How is AMAF tied to AMCO (the Monaco Association of Compliance Officers), and what are some of the projects in progress?
AMCO was founded in 2000 with the support of AMAF and SICCFIN. The Chairman of AMAF and the Director of SICCFIN are honorary members. The association includes Compliance Officers from different professions governed by law 1,362 of 3 August 2009. Its role is to ensure compliance with legal, regulatory and ethical standards.
The main objective of the compliance function is to protect the reputation of business, and therefore Monaco's financial industry. On behalf of its members, AMCO liaises with the authorities, notably SICCFIN and professional bodies like AMAF. Currently, we are focusing on the national transposition of the EU’s fifth AML directive; AMCO has contributed some observations and comments. We are also working on the amended law regarding the General Data Protection Regulation (GDPR) and the new National Risk Assessment (ENR2). This aims to identify, assess and understand potential and actual risks which the Principality faces in terms of money laundering and terrorist financing. The assessment procedure is based on the World Bank’s methodology, and we are very mindful of the result, as well as MONEYVAL’s fifth assessment cycle.
As Chairman of the AMAF Professional Certification Committee, the financial industry’s reputation is very important to you...
Yes, which is why professional certification is such a major project. Our professionalism must be in line with the biggest financial industries worldwide. On the initiative of AMAF, the Monaco Government created a mandatory professional certification system in 2014 in partnership with the International University of Monaco (IUM), including technical and ethical training modules. Then in 2018, AMAF organised a Privacy certification, a mandatory training system on protecting clients’ private lives, underlining the duties of professional secrecy, privacy and discretion.
We are now working on a Certification for Compliance Officers. We are striving for a financial industry with an excellent reputation and expert employees.
