At the end of October, part of the Philip Sidney team visited the Central Bank of Morocco. At the Central Bank’s training location in Rabat, Marlène Jans and her French colleague Damien Romestant gave three days of training on anti-corruption and bribery. This training was the result of a Council of Europe tender process won earlier this year by Philip Sidney thanks to its particular expertise.
A key objective of the Council of Europe is to promote unity between the Member States, in particular by concluding treaties between them. The most important of these is the European Convention for the Protection of Human Rights and Fundamental Freedoms (ECHR), which has been signed by all Member States. Citizens may invoke provisions of the ECHR before an important body of the Council of Europe: the European Court of Human Rights. This organisation also monitors the implementation of conventions on the prevention of torture. In addition to human rights, the Council of Europe is also active in other areas. For example, the Council of Europe promotes cultural diversity in Europe, including in the field of architecture, TV and film productions.
The Council of Europe had invited Philip Sidney to contribute to two training courses in Rabat during a mission. On Monday 22 October, Marlène and Damien were welcomed by the Secretary of the Executive Board of the Central Bank. During the first training course – which took place from 22 to 24 October – the Central Bank’s senior staff, division managers and department heads (a total of approximately 40 people) were trained in risk analysis in relation to corruption and bribery. The training was provided in collaboration with ICPC employees. The ICPC is the Instance Centrale de Prévention de la Corruption, a centrally operating institution that fights corruption in Morocco see (http://www.icpc.ma/wps/portal).
During the three-day training, ICPC staff first presented an overview of international laws and regulations on corruption and bribery. The work of Transparency International was also discussed see (https://www.transparency.nl/). Next, Marlène and Damien discussed the approach to risk analyses in more detail. It soon became clear that focusing only on hard controls is not enough to identify and control the risks in their entirety; after all, risks such as corruption and bribery are very much related to behaviour and culture (the risks of behaviour and culture are also referred to as ‘soft controls’; however, this is a rather unfortunate choice of words). That is why Marlène was able to weave her expertise in the field of behaviour and culture into the training on the third day. In addition, it was also explained how De Nederlandsche Bank (the Dutch Central Bank) supervises behaviour and culture, and together with the participants they investigated what they could learn from this.
The participants’ involvement in the subject was above expectations, and the discussions were very lively. This also became apparent during an exercise in which participants were asked to work together in small groups to develop a risk scenario in its entirety, think of mitigating measures, etcetera. The trainers were seriously challenged to answer even the most complex questions. There was also a great deal of demand for the draft for the audit of the soft controls, which Marlène had worked out. Fortunately, the contributions of Marlène and Damien were perceived as very positive and inspiring.
At the end of November Marlène and Damien will return for a two-day training. Compliance officers from Moroccan banks will also participate on that occasion and risk analyses and risk management relating to corruption and bribery will be discussed in more detail for the banks, both for the banks themselves and in their CDD and KYC activities with respect to their clients.
Obviously, we also contacted Tarik Bouziane, the CEO of RSM Morocco. Hopefully there will be an opportunity to meet Tarik at the end of November.