Jean-Philippe Ory: "We need to be visible if we are to be solicited"

2018 04 ory jean philippe

The Monegasque Association of Compliance Officers (AMCO), founded in 2000 on the initiative of the  Monegasque Association of Financial Activities (AMAF), plays a key role in the financial centre mainly in relation to the new regulatory challenges. Its chairman, Jean-Philippe Ory, Director of Compliance with Barclays, wants strong and clear communication on the Association’s role.

Can you remind us what is the exact role of a Compliance Officer?

The Compliance Officer must ensure that their institution complies with the legal, regulatory and ethical provisions. To do so, he or she pinpoints, assesses and controls all risks of failure to comply with obligations that may lead to legal, administrative or financial sanctions for the company and/or damage to its image.

The person in charge of compliance also has an information, training and advisory role, both for employees and for the institution’s corporate governance management.

What is AMCO’s role?

AMCO (Association of Compliance Officers in Monaco) now has 139 members who represent banks, portfolio management companies, company services providers and most non-financial professions (lawyers, notaries, auditors, law firms, estate agents and consultants) in Monaco.

AMCO plays an interconnection and experience sharing role for its members, who are Compliance Officers/Compliance Directors/Anti-Money-Laundering Managers etc.

As a Compliance Officer, it is important to have in Monaco a professional association bringing together all sectors of our professions so we are aligned to the same Monegasque and international standards.

In 2017, we increased our visibility among the supervisory authorities (SICCFIN, CCIN, CCAF and AMSN) and we have been solicited more.

When necessary, AMCO also plays a role in defending the interests of Compliance Officers and lobbying the Monegasque authorities.

This was the case recently, when our professional association was directly solicited by the National Council as a representative professional association to give our opinion on Law 972. On this occasion AMCO of course sent a letter to the National Council informing it of our proposed changes. But we also brought up the thorny issue of criminal risk that weighs on Compliance Officers in Monaco in some cases, and on this subject we have campaigned for strict alignment with the IVth European Directive.

In 2017, we also completely redesigned our website (www.amco.asso.mc) to facilitate connections between the represented professions. The site promotes exchanges and links between subgroups.

Finally, throughout the year we meet through sector-specific subgroups and we hold plenary information and training sessions.

What are AMCO’s plans for 2018?

As Compliance Officer in 2018 we have included in our programme an analysis of the impacts of draft law 972 on combating money laundering and terrorist financing, as well as the conditions for application of the European directives to Monaco, in particular the GDPR Directives on data protection and PSD II on international bank transfers.

We have not overlooked the challenges of digital in banking (the theme at our latest General Meeting, notably with a presentation of a Monegasque Fintech and a talk by AMSN). For the majority of our institutions, digital results in significant changes with the placing of Fintechs in the banking and financial landscape, the emergence of blockchains and crypto currencies, and our customers’ use of electronic signatures and voice recognition, not to mention new possibilities for aggregating their banking and financial data. Monaco’s banks have also raised all these issues.

To sum up, I wish to emphasise that most banking institutions in Monaco do apply the international standards. This no doubt explains the attractiveness of the financial centre for international customers and this point is not necessarily be perceived as such by most of our neighbouring countries.