Previously

Experts have made a clarion call for the full operationalisation of the code of corporate governance across all spheres of governance in the country, including the public and the organised private sector.

These calls become inevitable as the implementation of the code has been bogged down by bureaucracy, the experts maintained.

The Nigerian Code of Corporate Governance was issued in 2018 by the Financial Reporting Council of Nigeria (the “FRCN”) following the suspension of the National Code of Corporate 11(c) and 41(c) of the Financial Reporting Council of Nigeria Act, 2011. The Code is aimed at companies of various sizes across diverse industries, to institutionalise corporate governance best practices and promote public awareness of essential corporate values and ethical practices that will enhance the integrity of the business environment.

One of the leading lights in the effort to fine-tune the workings of the code is the Compliance Institute, Nigeria (CIN), which set the ball rolling at a two-day board retreat in Lagos over the weekend.

The virtual event tagged: ‘CIN: Expanding The Frontiers’ featured discussants drawn from professionals and officers within the regulatory compliance and enforcement departments of all private and public institutions across the country.

Speaking on the essence of the theme, Mr. Pattison Boleigha, President/Chairman of Board the CIN, said:

"The expansion drive has become more imperative, considering the dynamics of the ever-changing world occasioned by the global pandemic. Besides, the Institute’s resolve to leverage on its many successes recorded over the past six years of existence, is in tandem with the consistency in the quality and standard of its operations and drive to spread the gospel of compliance across various sectors of the Nigerian economy."

Going down memory lane, he recalled that

“Four years after starting operations, the Institute has definitely started seeing an increasing rate of companies embedding compliance practices in their businesses. The right tone for compliance in the country is gradually building momentum.”

Compliance, he maintained,

“Should be part of all organisation’s operations and need to be entrenched in all staff and compliance officers through training and awareness creation.”

"With present Membership of over 2,200, the Institute will continue membership drive by extending to all sectors including insurance, pension, micro finance, bureau de change, tax administration and the capital market,"

he stressed.

“In order to align with national and international outlook of compliance, the Institute, he hinted, is undergoing restructuring and reorganisation. The goal is to achieve a more national outlook and orientation by partnering with critical stakeholders within the public and private sectors. The Institute is also preparing for its eventual Charter application to the National Assembly.”

Source: The Nation Newspaper

Compliance functions have gone through a major period of growth and investment since the 2008 financial crisis. Many Nigerian firms have seen an increase in their compliance functions since then.

Pattison Boleigha, President, Compliance Institute, Nigeria (CIN) his colleagues in the board say the role of compliance in the financial services sector has changed significantly over the years. Compliance has and continues to evolve to meet the ever increasing demands and complexity of financial regulation, he says.

"Compliance has to evolve from traditional methods of managing compliance towards integrated risk management using automation to leapfrog compliance from gatekeeper to game changer"

“To meet the demands of a rapidly changing financial services industry, the compliance function has to shift its focus by using data insights to inform decision making and creating value for the business,”

he says.

He says there have been an increase in the use of robotics process automation and predictive analytics for risk assessment, monitoring and testing, complaints management, surveillance and regulatory reporting.

“This creates efficiency and saves costs in the long run,”

Boleigha says.

"As the Head-honcho, I am saddled with the responsibility of spearheading Africa’s emergence as a notable force in the global compliance chain. I am primarily responsible for overseeing the Compliance Programme for CIN in Nigeria and to ensure compliance with regulatory requirements and policies of Nigerian banks and other institutions. He is also responsible for safeguarding compliance and the reputation of Nigerian banks, whilst driving culture change within Nigerian business organisations"

he explains.

Pattison Boleigha, who assumed his position in 2017 has in the last five years and counting proven to the Nigerian compliance community a big task ahead of her.

The Compliance Institute for Banks and Other Financial Institutions in Nigeria Limited said it has reviewed its syllabus on different topics including corruption and anti-bribery for the institutions.

The President/Chairman of Board, Compliance Institute, Nigeria Mr Pattison Boleigha, said this during the second induction ceremony and annual general meeting of the Compliance Institute of Nigeria in Lagos.

He said,

“The CIN has reviewed its Designate Compliance Professional curriculum to include more contemporary compliance topics such as anti-bribery and corruption, ethics, governance and treating customers fairly. The examinations for award of ACIN certification will commence in 2019 and is also expected to cover telecommunications, manufacturing (pharmaceutical, foods and beverages), oil and gas and mining areas.”

In order to further enhance the value of its certification, he said, the institute was entering into a strategic partnership with a notable compliance body and the Association of Certified Anti-Money Laundering Specialists of Florida, United States of America.

The partnership with ACAMS, he added, would provide the CIN members with a wide range of compliance professional resources at highly discounted rates.

He added that discussions had commenced with the other sectors of the economy outside the financial services, such as law enforcement agencies, tax administration, telecommunications, manufacturing (pharmaceutical, foods and beverages), oil and gas, mining and government ministries, departments and agencies.

During the induction, he said, a total of over 150 newly certified members who successfully sat for and passed the institute’s compliance professional examinations were awarded Designate Compliance Professional.

Another 10 members, he added, were decorated with Associate, Compliance Institute, Nigeria after applying for and obtaining exemptions as compliance practitioners with the requisite qualifications and experience.

He added that 25 prominent compliance practitioners in Nigeria received the honorary Fellowship, Compliance Institute, Nigeria.

The president observed that the political and economic environment in Nigeria and globally had recently gone through tremendous changes with a fast pace in changes in regulation in all sectors.

He explained that the CIN was incorporated on 22nd January, 2015, as a ‘company limited by guarantee” to meet the fast pace of regulatory changes, by helping to build a compliance culture driven by compliance professionals.

Midwifed by the Association of Chief Compliance Officers of Banks in Nigeria, the institute was established to promote professionalism, facilitate cooperation and maintenance of compliance standards, he added.

He said,

“The institute continues to offer membership benefits on its website, such as on-line training facilities, webinar, podcasts, conferences and various learning resources to continually update knowledge."

“An ultra-modern office will be declared open as part of the induction event, courtesy of Polaris Bank Plc that provided the office space together with Sterling Bank Plc and Access Bank Plc who funded the interior design work.”

Source: PunchNG

The Compliance Institute of Nigeria (CIN) has stressed that with total compliance to the financial rules and regulations in the country, Nigeria will be able to attract huge flow of foreign investments.

CIN therefore stated that with its comprehensive training for compliance officers and professionals, it was poised to support authorities in enforcing regulations in order for Nigeria to gain respect in the comity of nations.

The leadership of the Institute led by its President, Pattison Boleigha, said at a media parley yesterday in Lagos that CIN is wholly aimed at curbing illicit fund flow and international money laundering.

According to Boleigha, the primary objective of the institute is to promote professionalism among compliance practitioners and the application of International compliance best practice through the promotion of the professional, status, image and credibility of its members with its accreditation and professional programmes.

We have a lot of training programmes for our professionals who will ensure all forms of corruption and money laundering are curbed in the system. Our training programmes which are ICT and conferences-based will help bring financial organisations to speed in the area of transparency and fairness.

He added that the Institute enforces compliance to financial regulations by training its officers who would effectively ensure total compliance in banks and other financial institutions, saying this is done through encouragement and facilitation of the exchange of information among members via cooperation, collaboration and coordination of efforts.

CIN president said the Institute which was registered on January 22, 2015, and commenced operations in 2017, was established to encourage, promote and revive the consciousness for regulatory compliance within and outside the financial industry in the country.

Boleigha added, the Compliance Institute Nigeria has so far conducted six sets of examinations for members from banking and other financial institutions for the award of the professional certificate of Designate, Compliance Professional (DCP) with over 400 members taking the examinations. We also offered an opportunity to grandfather compliance practitioners with the requisite qualifications and experience and will be awarding over 40 Associate, Compliance Institute, Nigeria (ACIN) and over 60 Fellow, Compliance Institute, Nigeria (FCIN) certifications. All the certificates will be officially awarded at our first inaugural investiture ceremony to be held on December 9, 2017 in Lagos Business School, Lagos.

We also intend to conduct a Diploma course on Customer Due Diligence, which would be targeted at the market facing and Customer Service staff of financial institutions, because these are the set of personnel who have direct contact with customers.

Source: Thisday Newspaper

In the Pattison Boleigha-led Compliance Institute, Nigeria and his colleagues in the boards, all poised to take compliance to the next level, have spotted the many challenges Nigerian companies face with navigating, monitoring and evaluating Nigeria’s regulatory landscape.

Two years ago, following its strategic alliance with the Centre for National American Security (CNAS), the growth has reflected in part, the post-financial crisis regulatory reform agenda-including not only resilience and-for banking-resolution requirements, but also a host of retail conducts, wholesale conduct, anti-money laundering, corporate governance, more intrusive supervision and individual accountability.

“Compliance has to evolve from traditional methods of managing compliance towards integrated risk management using automation to leapfrog compliance from gatekeeper to game changer. To meet the demands of a rapidly changing financial services industry, the compliance function has to shift its focus by using data insights to inform decision making and creating value for the business,”

he revealed.

He further noted that there has been an increase in the use of robotics process automation and predictive analytics for risk assessment, monitoring and testing, complaints management, surveillance and regulatory reporting.

Compliance can only support and challenge the business effectively if it evolves in response to changes in the business itself and is fit for future financial services.

It is instructive to note that the irrepressible Compliance Institute, Nigeria, has over the years increased its resources and have widened their range of tasks, with a dramatic increase in their monitoring and surveillance activity, whether manual or substantially automated.

In the words of Abimbola Adeseyoju, Chairman, Communications and Partnership, Compliance Institute, Nigeria (CIN),

"Compliance needs to keep up with the pace of change here, in particular to deliver compliance with information, technology security, the control, security and privacy of data, artificial intelligence, cyber security, outsourcing, anti-money laundering regulatory reporting and associated obligations."

According to Isioma Gogo-Anazodo, Chairman, Committee Programmes, Education and Examination; Compliance Institute, Nigeria (CIN),

“As an institution, we are making strategic investments to ensure a more proactive approach to risk identification and a robust industry-centric outcome, by utilising, and engaging with evolving technology and data analytics. Our up-to-date learning virtual learning and industry-specific webinar series is setting a tone for the future of a compliant Nigerian business climate"

Speaking on the next steps in transforming compliance in Nigeria and Africa, Isah Ibrahim, Vice President, Compliance Institute, Nigeria (CIN) has said that it has recognised how the business landscape is changing. In line with that, it has changed its business model.

Source: The Nation Newspaper

At a recent meeting of African banks, regulators and industry bodies from 12 countries, called for the creation of a pan-African sanctions list, similar to the US Treasury’s OFAC list.

Accuity, the global provider of risk and compliance, payments and know-your-customer solutions, met with the Association of Certified Compliance Professionals in Africa (ACCPA), commercial banks, GIABA, central banks, FIUs, and universities to discuss four key issues relating to the future of compliance in Africa – Sanctions, PEPs, Compliance and Trade-Based Money Laundering (TBML).

Hugh Jones, CEO at Accuity, said:

“We worked with the ACCPA to share international and regional experience. Our objective was to better understand the African perspective on a range of compliance issues and work together to find recommendations for how to address these issues in Africa.”

On Sanctions, there was broad consensus that Western sanctions lists solve global problems whereas an African list, with consolidated sanctions within the region, would be the best way to target distinctly African issues.

Idrissa Diop, Group Head of Compliance at EcoBank summarised:

“With international sanctions, we see a major imbalance between Western practices and local African practices. For African banks, monitoring international sanction lists is not an issue, since the information is readily available and regularly updated. Local banks would benefit from regular updates of the sanctions issued by African authorities, in order to secure their respective licences.”

Pattison Boleigha, Chief Conduct & Compliance Officer at Access Bank Plc commented:

“Compliance in Africa gets little protection from local law and this creates a barrier to global best practices. A greater degree of political will for local regulation and enforcement is necessary to drive change.”

There was debate around which authority should assume responsibility for facilitating this change, with most participants agreeing that any solution would need to be politically-driven. Participants questioned whether the African Union could be called upon to implement a sanctions list for the continent, similar to the European Union’s sanctions list.

Adama Coulibaly, Director General of GIABA, suggested:

“Boosting compliance in Africa requires a comprehensive approach. As it goes beyond mere compliance with laws and technical standards, compliance raises the need to create and implement a global network that may promote the sharing of information and best practices in real time.”

All agreed the solution will involve collaboration between regional and central banks and will need regulatory and government support.

Other observations were:

Politically Exposed Persons (PEPs):

• Africa should adopt a wider definition of PEPs than the West given the number of different organisations involved in political activity.


• The notion of Prominent Influential Persons (PIPs) was raised, with participants stressing the importance of local influencers, such as religious leaders or chiefs of provinces. The term ‘PIP’ was recently identified by the Banking Association South Africa as a deviation from the internationally accepted terminology.

Regional/local needs in the context of international regulation:

• A local sanctions list and the potential for fines or penalties issued by local regulators would be taken seriously and would help to raise compliance standards across the continent.


• Criminal behaviour appears to be moving to smaller, regional banks.


• KYC is difficult when a number of addresses share the same utility bill.


• “Derisking” by larger global banking institutions will accelerate and the unbanked will find alternatives to meet their demand which introduces risk.

Trade-Based Money Laundering (TBML):

• This is a growing issue but there is a lack of regulatory pressure, with banks currently suffering little to no monetary loss if TBML occurs.


• The majority of global trade transactions are made in US dollars and are therefore subject to OFAC standards – all members of the round table agreed with the importance of respecting and complying with such international regulation.


• Accuity representatives highlighted the need to identify and prevent the shipping of dual use and controlled goods lists to sanctioned or high risk jurisdictions.

Introduction

The Commissioner of Insurance, Mr Thomas, The Directors and Departmental Heads, Distinguished Members of the Press Ladies and Gentlemen. It is a great honour to meet with the Commissioner today.

The Compliance Institute, Nigeria (CIN), registered as the Compliance Institute for Banks and other Financial Institutions, and its Board members have always looked forward to this visit. Firstly, we want to thank the Commissioner and the entire management and staff of NAICOM for agreeing to meet with the Institute. .

The desire to visit the Commissioner was borne out of the Institute’s conviction that partnering with NAICOM fits into CIN’s goal of promoting the Compliance culture within the Insurance industry in Nigeria and towards greater accountability and reduction in corruption and illegal activities in the country.

The Institute was established in January 2015 to encourage, promote and revive the consciousness for Regulatory Compliance in Nigeria. This is supported by the desire to inculcate the culture and practice of complying with rules and regulations in all organisations nationwide as a way of reducing illegal and criminal activities in Nigeria. Compliance as a global practice across all sectors of the economy is an act of being in conformity with applicable Laws, Rules and Regulations.

Membership & Stakeholders

The Compliance Institute, Nigeria (CIN) is open to all individuals and Institutions who believe in the power of obedience to rules and regulations in changing society for the better.

Presently, CIN has more than 2,500 members across all sectors of the economy including Association of Chief Compliance Officer of Bank in Nigeria (ACCOBIN), Access Bank Plc, Sterling Bank Plc, First Bank Plc and DataPro Limited as promoters.

The Central Bank of Nigeria (CBN), Securities & Exchange Commission (SEC), National Insurance Commission(NAICOM), Economic and Financial Crimes Commission (EFCC), Nigeria Customs Service (NCS) Nigeria Police (NP), Department of State Services (DSS), Nigerian Financial Intelligence Unit (NFIU), Special Control Unit Against Money Laundering (SCUML), National Drug Law Enforcement Agency (NDLEA) and the Inter-Governmental Action Against Money Laundering in West Africa among many other key Stakeholders have all provided the needed backbone for the Institute since inception due to its role at promoting the culture and practice of Compliance among all banks and other financial institutions in Nigeria.

Compliance as a Control & Risk Management Tool

In any organisation committed to conducting its affairs more efficiently and effectively, Compliance is seen as a preventive, detective, corrective and directive control against Risks and threats that could negatively affect its sustainability.

It enables the organisation to set up internal control measures that will debar, monitor and train employees and directors from engaging in unprofessional and unethical actions associated with misconduct or illegal and criminal activities.
Every forward-looking company operating in this digital economy puts Compliance at the heart of its affairs.
This has therefore made Compliance, as a discipline, one of the most sought after in Public & Corporate management.
Compliance duties are also entrenched in Risk Management & Assessment, Legal, Internal Control and Audit functions.

Restructuring the Institute

Historically, Compliance started in the early 90s within the Financial Industry as a way of preventing abuse, misuse and breach of financial products and services for illegal and criminal activities.
This explains the initial nomenclature given to the Institute. However, Compliance has grown into a global and industry-wide application to ensure the soundness, stability, security and safety of all Corporations and Businesses.

In order to align with this National and International outlook of Compliance, the Institute is undergoing restructuring and reorganization. The goal is to achieve a more National outlook and orientation by partnering with critical stakeholders, such as NAICOM, within the public and private sectors.
The Institute is also preparing for its eventual Charter application to the National Assembly.

CIN CERTIFICATION PROGRAMMES

The Institute has Certification Programs designed to empower and upskill employees and Directors within the financial industry and designated non-financial institutions to carry out their statutory obligations regarding Compliance management.

These Certification Programs include:

• The Designate Compliance Professional (DCP) Certification.


• The Associate Compliance Professional (ACIN) Certification.

Solicitation for Support

The Institute therefore requires the support and leverage of the Commissioner of Insurance and NAICOM to achieve its dreams and aspirations.
Consequently, It is our desire to engage the management of NAICOM to achieve the following for the Institute:

1. Make the Certification Programs compulsory for all Compliance Officers within the Insurance Industry.
2. Register critical members of staff of NAICOM in the underlisted departments and units as members of the Institute.
3. Compliance.
4. Legal.
5. Internal Control.
6. Risk Management.
7. Enforcement and Monitoring.
8. Licensing and Regulation.
9. Audit.
10. Confirm the Commissioner as an Honorary Fellow of the Institute at the 5th Annual Induction scheduled to be held on the 11th of December, 2021.
11. Allow critical staff members of NAICOM to register for the 2021 International Compliance Conference (ICC) organized by the International Federation of Compliance Association (IFCA), of which the Institute is a major stakeholder, taking place globally between the 4th and 8th of October 2021.

Conclusion

We express our gratitude to the Commissioner for the opportunity given to us and look forward to working together to strengthen the ability of the Institute to fulfil its mandate.

Thank you.
Pattison Boleigha
President, Compliance Institute, Nigeria