Gregory Moscato, holder of a PhD in finance, directs the Master in Finance at the International University of Monaco (IUM). In charge of the Finance Certification programme at IUM since 2014, he has been mandated by the Monegasque Association of Financial Activities to supervise the new Confidentiality Certification programme. Meet him.
Why a Confidentiality Certification?
This certification stems from an AMAF initiative. It is part of Ministerial Decree 2018-367 of 30 April 2018 which mandates the Monegasque Association of Financial Activities (AMAF) to implement it. It involves three types of obligation:
- professional secrecy
- the principle of confidentiality
- the duty of discretion.
There are strong image stakes. Protection of customer information is an essential element in the Monaco financial and banking centre’s attractiveness.
The Sovereign Prince has made some major decisions, in line with history, with greater financial transparency. This may have raised some concerns: will the information specific to each customer of a financial institution be well protected? With this certification, the financial centre is sending a strong message on the strictest respect for confidentiality, which reassures customers.
How is the certification put into place in practical terms?
It was launched in October 2018. All employees and directors of entities approved by the CCAF (Financial Activities Control Commission) must complete a two-hour training session and then sign the Monegasque Association of Financial Activities confidentiality charter, which emphasises the existing obligations reflected in the legislation.
That means organising 3000 training sessions at IUM. We have set up a dedicated platform so that the institutions may register their employees.
Three trainers are responsible for this certification, the content of which is validated by AMAF.
The training emphasises the legal framework, the context of the certification, and strengthens the culture of confidentiality. The rules and stakes are detailed and much emphasis is given to interaction between trainers and trainees. It is necessary to define precisely which information is to be shared, in which cases, and with whom.
At what point are you now?
We have organised 100 sessions of 30 people, to be delivered over 18 months. The institutions are playing the game very proactively, enabling more than 1800 people to be trained by the end of June.
For its part, the CCAF will begin audits in order to confirm the fact that the financial entities’ employees have in fact been trained. Their commitment to comply with the confidentiality rules is evidenced by individual signatures of the confidentiality charter, which their employers have a copy of.
