Isah Aminu Buhari is the Vice President , Compliance Institute, Nigeria (CIN) and Co-Chair, Association of Certified Anti -Money Laundering  Specialists (ACAMS). He speaks with Adedayo Adejobi on the Apex Bank’s competency framework, the institute’s alliance with Center for a New American Security, IFCA and how Nigeria’s compliance industry has become exposed to pragmatic, evidence-based research, principled national security debates and defense policies…

 Could you shed light on the Compliance Institute Nigeria’s recognition by the IFCA and acceptance by all regulatory authorities by virtue of its roots being from the ACCOBIN which is approved by Central Bank of Nigeria Circular and the Apex Bank’s competency framework. What does the alliance portend for the compliance industry and Nigeria?

The Compliance Institute for Banks and Other Financial Institutions in Nigeria Ltd/GTE, also known as “Compliance Institute, Nigeria” (CIN) was registered in January 2015. The Institute was established to encourage, promote and revive the consciousness for regulatory compliance within and outside the financial industry in the country. The Institute seeks to build a body of professionals and corporate organisations that would be recognised for integrity, professionalism and strict adherence to regulatory and non-regulatory standards in and outside the business environment. It draws membership from employees and directors within the financial industry while its equally open to interested members of the Nigerian public. The Compliance Institute, Nigeria has come a long way since inception, receiving generous acceptance from stakeholders. Today, membership of the Institute is considered a pre-requisite for working in the compliance department of any financial institution in Nigeria. The Institute is, therefore, a generally recognised body for compliance professionals within the financial industry in Nigeria

It may interest you to know that the Compliance Institute, Nigeria (CIN) is a brainchild of the Association of Chief Compliance Officers of Banks In Nigeria. (ACCOBIN). For emphasis, ACCOBIN is highly recognised not only by the financial institutions but also by the regulatory authorities such as the CBN, NDIC, SEC, NAICOM and Law Enforcement Agencies (LEAs) such as the EFCC. To strengthen and enhance the acceptability of CIN, the Institute is currently engaging the CBN with a view to incorporating CIN certifications into the CBN competency Framework Policy. Regarding the potential impact of the alliance between the Compliance Institute, Nigeria (CIN) and the regulatory authorities, I can say with confidence that by virtue of its mandate and the strategic relationship with regulatory authorities, the Institute would play a crucial role in entrenching optimal regulatory compliance philosophy among financial institutions for a mutually beneficial relationship.

The Compliance Institute Nigeria mobilized Nigerian Compliance professionals and those across Africa to participate in the first IFCA ICC attended by participants from all over the world ,with Nigeria recording the second largest participants turnout after Spain. What does Nigeria’s participation in this global platform prognosticate for Nigeria and Africa?

As part of Compliance Institute, Nigeria’s (CIN) international partnership drive, the Institute engaged and obtained membership of the International Federation of Compliance Associations (IFCA). IFCA was formed in Dublin on November 23, 2010.  It is the umbrella organisation for professional bodies that specialise in the practice of compliance. Membership is open only to not-for-profit associations and professional bodies, such as Compliance Institute, Nigeria (CIN), that have a primary focus to promote compliance, ethics and the career progression of their respective members. So, in effect, membership comprises national compliance bodies from around the world that have been established for the benefit of the compliance profession and its members. In a nutshell, the purpose of IFCA is to be the global voice of the Compliance Profession.

As you might be aware, the CIN became a full member of IFCA on September 22, 2020. By becoming a member of IFCA, the CIN gained access to a global platform amongst other Compliance professionals and other stakeholders. It means the CIN certifications will have global recognition. It also means the Compliance Institute, Nigeria (CIN) will on an on-going basis, have access to international professional networks and best practices.

The CIN and its members have already started reaping the benefits of IFCA membership by attending the first IFCA ICC Virtual Conference held on 16-20 November 2020. I am happy to state that the Compliance Institute, Nigeria (CIN) played a key role towards the success of the conference by mobilising compliance professionals across the African continent to participate in the global conference with Nigeria recording the second largest participants turnout after Spain. This has in no small way exposed participants to best compliance practices, potentially improving their capacity, and also improved the global visibility of our great Institute

Furthermore, along with IFCA membership also came the opportunity for some members of CIN BOT to participate on global IFCA Committees. Compliance Institute, Nigeria is represented on IFCA Education Committee and IFCA 2021 International Congress Planning Committee by BOT Directors Isioma Dagogo and Abimbola Adseyoju, respectively. By this, it is clear to see that the Compliance Institute, Nigeria now has a say in the global compliance profession.

 What effort is the Compliance Institute Nigeria making with National Assembly to get a charter?

In its quest to become chartered by an Act of the National Assembly , the Compliance Institute, Nigeria has engaged a consultant to facilitate the achievement of this objective. The Institute intends to engage the Central Bank of Nigeria to sponsor a Bill for a charter at the National Assembly. This will no doubt lend more credibility to the process and as you know there is a nexus between enhanced regulatory compliance and the promotion of a sound financial system which is a core mandate of the Central Bank of Nigeria. We are committed to the course we have chosen for our great Institute and our dream is for the Central Bank of Nigeria to become charted by the end of 2021.

 The Institute is not profit making, so how have you been able to achieve the profit of improved knowledge of Compliance in Nigeria?

As you are aware, the Compliance Institute, is guaranteed by trustees and as such it is not a profit-making body. Right from inception, the Compliance Institute, Nigeria Board Of Trustees directors have been working on pro-bono. As the Institute’s membership base increased over the years, revenue acquired largely from membership fees are used to fund the institute’s activities. Additionally, most of the institute’s operations are carried out virtually and this has further reduced overhead costs over the years. The institute has since achieved break-even and is already self-sustaining. The success and achievements recorded by the Institute thus far, was out of sheer sacrifice and astute management and direction provided by the Board Of Trustees directors under the leadership of Mr. Pattisson Boleigha.

Following the new Nigerian Presidential order on COvid-19, the Compliance Institute Nigeria is championing compliance of the COVID-19 regulation. Tell us more about the compliance twist to the pandemic?

The COVID-19 pandemic has led to unprecedented global challenges, human suffering, economic disruptions and an increase in COVID-19-related crimes. Since the start of the pandemic, criminals have sought to exploit the crisis to commit scams, fraud and cybercrime. When we were looking at the Institute’s prospects and challenges in the first weeks of 2020, the first reports about Covid-19 were just emerging. Then everything changed. Little did we know how it would come to change both our personal and professional lives. We could therefore be forgiven for not featuring it as part of our Compliance Challenges as practically no one in the world took it seriously enough, except perhaps China.

From inception, the operations of Compliance Institute, Nigeria have been IT-driven. Though it has physical presence, Compliance Institute, Nigeria was created to operate almost virtually. Therefore, when COVID-19 national protocol required working virtually Compliance Institute, Nigeria was more than ready, and we immediately adapted the protocol seamlessly. Classroom lectures, Board Of Trustee directors meetings, Annual General Meeting and induction ceremonies were conducted virtually and with ease by the secretariat staff who also had to work remotely under close monitoring by the Board Of Trustee.

In support of government’s presidential directives on Covid-19, the Compliance Institute, Nigeria is championing compliance with COVID-19 measures. As the restrictions associated with the pandemic start to ease in 2021, many organisations will never be the same again. For smaller businesses, it is easier to return to a full office working model than big organisations. However, employee expectations have changed, forever. Whilst it is envisioned that many technology companies will move to a full remote working model after the pandemic, for financial services, the most likely outcome is that a significant percentage of the workforce will be working remotely.

 What will this mean in terms of compliance?

The biggest change is that firms will need to look at their compliance risks again, but this time on a longer-term basis. The management of conduct risk is the biggest challenge in these circumstances. Conduct risk is broadly defined as any action of a financial institution or individual that leads to customer detriment or that has an adverse effect on market stability or effective competition. The issues are many and varied, including the management of front office staff, ensuring that documentation is properly maintained and disposed of, trades are carried out in a timely manner and client access via telephone/online is maintained when necessary. Remote oversight is likely to form a more prevalent component of risk management, including the management of compliance risks, which also includes the prevention of market abuse, inappropriate advice and lack of adherence to sales-related procedures. As we move deeper into year 2021, financial institutions should seek to develop an understanding of the emerging regulatory scope, including new risk environment in which they will be operating. In addition to managing their compliance resources and training compliance staff, financial institutions will need to review their compliance resilience to adequately adapt to the ever-changing regulatory landscape, on an ongoing basis.

As COVID-19 infections have mushroomed, the few months of 2021 are likely to be taken over by the immediate response to the pandemic. But beyond that, vaccination offers the hope of a more stable future – an environment where organizations can, and will be expected to, focus on compliance again.

 The Compliance Institute Nigeria is in strategic alliance with the the Centre for National American Security (CNAS). What does this alliance portend for Nigeria, the Compliance Industry?

The Center for a New American Security (CNAS) is an independent, bi-partisan, non-profit organisation that develops strong, pragmatic, and principled national security and defense policies. CNAS engages policymakers, experts, and the public with innovative, evidence-based research, ideas, and analysis to shape and elevate national security debate. A key part of its mission is to inform and prepare the national security leaders of today and tomorrow. CNAS is located in Washington and was established in 2007. Since the Center’s founding, its work has informed key United States of America’s strategic choices and has been acted on by Republican and Democratic leaders in the executive branch and on Capitol Hill.

CNAS in conjunction with CIN held its first and second workshops in May 2019 and September 2020, respectively. The first workshop provided practical advice on North Korea sanctions and counter-proliferation finance standards for compliance officers in Nigeria. It covered key aspects of compliance, including United Nations Security Council Resolutions and other relevant international-level sanctions on North Korea; FATF recommendations and guidance on proliferation finance; and typologies of North Korean sanctions evasion activities, including a review of several relevant case studies, including case studies in Africa. The second workshop was virtual and provided Sanctions Implementation Update on significant developments on sanctions since August 2019; trends in the use of cryptocurrency to evade sanctions and compliance best practices for companies involved in cryptocurrency, and Challenges in Sanctions Compliance.

Hundreds of our members attended the two workshops and enhanced their capacity on sanctions and cryptocurrency issues and why complying with these sanctions are very important. The workshops were rich, educative and got quite a lot of positive feedback from our members. Clearly, CIN’s collaboration with such a strategic organisation as CNAS, has exposed our Institute to global visibility and recognition.