Nearly 200 participants in the different sectors of the Moroccan financial market were subject to inspection operations between 2020 and 2023. This period was marked by an intensification of controls carried out by the Moroccan Capital Market Authority (AMMC) and by a notable increase in inspection missions, which went from 26 missions between 2020 and 2021 to 47 missions between 2022 and 2023.
According to the AMMC, these inspections mainly focused on the methods of collecting subscriptions by the members of the investment group during public offers, including the technical means used and the control systems put in place to ensure compliance with the subscription terms. . They also assessed the system for combating money laundering and the financing of terrorism, in particular the aspects linked to the identification of customers and beneficial owners, as well as the traceability and monitoring of operations in this area.
Since the entry into force of the Authority’s new regulatory system, “the division responsible for monitoring and combating money laundering has seen its workforce increase thanks to the creation of four inspection teams made up of 17 people dedicated to inspection missions”, according to its annual report addressed to the Head of Government.
In this context, the AMMC has adopted a new type of inspections to guarantee regular presence of teams with stakeholders and market infrastructures. This results in SCAN7 general inspections, SCOP8 thematic inspections aimed at identifying good and bad practices, and SCRIN9 one-off inspections triggered following the appearance of a new risk.
The Authority also examined the system for reporting suspicions to the Financial Intelligence Processing Unit (UTRF), as well as relations with the National Committee responsible for the application of sanctions resulting from resolutions of the Security Council of the linked to terrorism, the proliferation of weapons and their financing.
The inspections also covered the internal control systems of the management companies of Undertakings for Collective Investment in Transferable Securities (UCITS) in terms of identification, management and control of risks, as well as the development of control plans and reporting results to governance and management bodies.
The conditions for carrying out the activities of UCITS depositaries and the organization of the structures responsible for maintaining securities accounts were also assessed. These evaluations made it possible to develop a map of good and bad practices, to identify the tools necessary to develop the required means and to point out the difficulties linked to the exercise of depositary functions.
Furthermore, the system used by management companies to evaluate the assets and liabilities of the funds under management was scrutinized. This includes the organization of the assessment process, the analysis and monitoring of assessment methods, as well as the related policies and procedures.
It should be noted that “type” inspections SCAN » are planned on an annual or multi-year basis and cover all the activities of the stakeholders. The inspections SCREEN », as for them, are triggered upon receipt of information signaling new risks or carried out according to a risk management framework.
At the same time, inspections of the type “ SCOP » consist of short-term thematic checks targeting a specific subject and carried out simultaneously with several stakeholders. Their main objective is to compare the specific practices of stakeholders in a given field in order to identify good and bad practices based on benchmarks (national laws, international standards, etc.).
