Financial Crime World

Here is the converted article in Markdown format:

Morocco’s Anti-Money Laundering and Counter-Terrorist Financing Measures Under Scrutiny

RABAT - Morocco’s efforts to combat money laundering (ML) and terrorist financing (TF) have been marred by a lack of coordination among concerned departments and institutions, according to a recent report.

National Authority for Anti-Money Laundering and Combating the Financing of Terrorism (UTRF)

The report highlights the importance of UTRF, which plays a key role in collecting, analyzing, and disseminating financial intelligence. However, it notes that UTRF’s ability to coordinate policies on ML is hampered by a deficiency in the legal text, which only enables it to do so without considering TF.

Investigations

The report emphasizes the need for strategic analysis to derive methods and contribute to setting recommendations and guidance that would improve the whole AML/CFT regime. However, it notes that such analysis is lacking among other competent authorities.

  • The report highlights the lack of expertise among investigators in ML operations, financial investigation techniques, predicate offenses, and technical means and tools.
  • This has resulted in a low number of cases being investigated and prosecuted, with only two convictions out of eight judgments for the period 2008-2016.

Feedback and Reporting

The report notes that there is no feedback between UTRF and reporting entities, which affects their ability to report and enhance the quality of reports submitted. Additionally, UTRF is not informed of the outcomes of reports by the Public Prosecution.

Recommendations

To address these issues, the report recommends:

  • Strengthening coordination among concerned departments and institutions
  • Improving investigative expertise
  • Enhancing the use of financial intelligence

UTRF Board Composition

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)
  • Directorate General for Savings and Social Security (DGSN)
  • Royal Gendarmerie
  • Central Agency for Management and Planning (CAD)
  • Moroccan Association of Mortgage Credit Institutions (AMMC)
  • Exchange Office

The board deliberates on strategic tasks, including proposing necessary legislative, regulatory, or administrative reforms in the AML/CFT field to the government. However, there is no coordination of policies and activities in relation to combating the financing of proliferation of weapons of mass destruction.

Systemic Risk Supervision and Coordination Committee

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. The committee is established under Article 108 of the law concerning credit institutions and similar bodies.

UTRF’s Role

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, it forwards the results of its work exclusively to the competent Public Prosecution, while TF cases are shared with a mini-committee headed by UTRF before dissemination.

Use of Financial Intelligence

UTRF relies on the G oAML software to analyze STRs received from reporting entities, mainly from banks and Money Transfer Services (MVTS), which saves time and efforts in exchanging information on STRs. UTRF has also given users accounts to reporting entities and supervisory authorities.

Strategic Analysis

UTRF’s strategic analysis 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. However, such analysis is lacking among other competent authorities.

Confiscation

Confiscation of criminal assets is an important aspect of anti-money laundering efforts. However, the report notes that confiscation of criminal assets in Morocco has been limited due to a lack of expertise and resources.

Overall, the report highlights the need for stronger coordination among concerned departments and institutions, improved investigative expertise, and enhanced use of financial intelligence to combat ML and TF effectively in Morocco.