Morocco’s Anti-Money Laundering and Counter-Terrorist Financing Efforts: Coordination and Cooperation Crucial
Rabat, Morocco - The fight against money laundering (ML) and counter-terrorist financing (CFT) is a top priority for Morocco. To tackle this issue effectively, the country’s main authority in charge of coordinating AML/CFT policies, the UTRF, plays a key role in collecting, analyzing, and disseminating financial intelligence.
The UTRF Board
The UTRF board consists of 13 members representing nine competent authorities, including:
- Ministry of Finance (MOF)
- Ministry of Justice (MOJ)
- Ministry of Interior (MOI)
- Bank Al-Maghrib (BAM)
- Direction Generale de la Surveillance du Marche des Valeurs Mobilieres (DGSN)
- Royal Gendarmerie
- Central Authority for the Prevention of Money Laundering and Terrorist Financing (CAD)
- National Authority for Securities and Stock Exchange Commission (AMMC)
- Exchange Office
The UTRF board deliberates on strategic tasks with the head of the organization, proposing necessary legislative, regulatory, or administrative reforms in the AML/CFT field to the government.
Coordination Challenges
Despite its efforts, there is a lack of coordination of policies and activities in relation to combating the financing of proliferation of weapons of mass destruction. The Systemic Risk Supervision and Coordination Committee, chaired by the governor of BAM, aims to promote coordination in the field of macro-preventive supervision of the financial sector, including issues related to combating ML and TF.
Financial Intelligence
UTRF plays a key role in collecting, analyzing, and disseminating financial intelligence, receiving STRs (Suspicious Transaction Reports) and other reports deemed useful for its work. However, the number of disseminated TF cases is low, and there is no feedback at two levels - among UTRF and reporting entities, which affects their ability to report and enhance the quality of reports submitted.
Analysis and Recommendations
UTRF relies on governmental and non-governmental sources to obtain information, including databases of supervisors and LEAs (Law Enforcement Agencies). It also requests information from reporting entities and supervisory authorities. The organization uses GOMAL software to analyze STRs received from reporting entities, saving time and efforts in exchanging information on STRs.
However, strategic analysis conducted by UTRF requires a deeper understanding and further procedures to derive methods and contribute to setting recommendations and guidance that would improve the whole AML/CFT regime.
Investigating and Prosecuting ML Offenses
The National Security Judiciary Police (NSJP) has created an office for combating economic and financial criminality, mandated to investigate ML offenses and implement decisions regarding ML investigations. However:
- Investigators’ expertise in ML operations, financial investigation techniques, predicate offenses investigations, and technical means and tools is weak.
- The investigative authorities also lack knowledge of the types of ML cases, including money self-laundering, third-party laundering, and where the predicate offense actually occurred.
Confiscation of Criminal Assets
Confiscation of criminal assets is a crucial aspect of AML/CFT efforts. However, Morocco’s confiscation regime needs improvement to effectively combat money laundering and terrorist financing.
Conclusion
Overall, coordination and cooperation among competent authorities are essential to enhance the capacities of reporting entities and improve the effectiveness of AML/CFT measures in Morocco.