Status and Reporting Line of Chief Compliance Officers

NK OF NIGERIA lation Department Sarki, Abula Tel.09-46237401 ........

· E-mail: fprd@cbn.gov.ng 17th November, 2014 FPR/CIR/GEN/04/012 CIRCULAR TO BANKS, DISCOUNT HOUSES AND OTHER FINANCIAL INSTITITONS STATUS AND REPORTING LINE OF CHIEF COMPLIANCE OFFICERS We refer to our circular referenced BSD/2/2002 and dated 8th August, 2002 which directed banks and other financial institutions to appoint Chief Compliance Officers (CCOs) not below the grade of a General Manager and compliance officers (COs) at managerial level in their branches; and our reminder of 23th May, 2014 referenced BSD/DIR/GEN/LAB/07/013.

Representations from banks as well as the issuance of the New Banking Model have .

necessitated the need for a review of our circular of August, 2002. Accordingly, the required minimum grades for the appointment of CCOs and COs have been reviewed as provided herein:

Category of Institution	Educational	and	Minimum Status	Recommended
		Additional Certification
Experience
Requirements
Banks/Specialised	Banks	As provided in the Fit	International	Compliance
and		Proper	Association Certificate (ICA).
withinternational authorisation,		General Manager
Systemically	Important	(Approved Persons)	or	Certified Anti	Money
Financial Institutions (SIFIs),	Framework for	Laundering	Specialists
and Foreign Banks		(CAMS), or Certified Fraud
		Examiner (CFE)

e	Recommended
Category of Institution	Educational	and	Minimum Status
Experience	Additional Certification
Requirements
Commercial	As provided in the	Deputy General	ICA, CAMS, CFE
Banks/Specialised	Banks	Fit and	Proper	Manager
with national authorisation	(Approved
that are not SIFIs	Persons)
Framework	for
Deputy	General
Managers
	Commercial	As provided in the	Assistant General	ICA, CAMS, CFE
Banks/Specialised	Banks	Fit	and	Proper	Manager
	with regional authorisation	(Approved
that are not SIFIs; all	Persons)
merchant	banks	and	Framework	for
discount houses	Required
Regulatory
as a see	Function	(Chief
Compliance Officer)
do
Microfinance Banks	Head, Compliance for	ICA, CAMS, CFE
	State and National
(Units, State and National)	-do-	Head of Department
	for Units
Primary	Morigage Banks
(PMBs)	Assistant General	ICA, CAMS, CFE
	Manager for National
-do-	PMBs
	Head of Department
	for State PMBs
Bureaux De Change	Manager Operations	ICA, CAMS, CFE
-do-
Finance Companies	-do-	Head of Department	ICA, CAMS, CFE
	Page 2 of 3

: ++

	Recommended
Category of Institution	Educational	and	Minimum Status	Additional Certification
	Experience
	Requirements	ICA, CAMS, CFE
	Assistant General
Development	Finance	Manager
Institutions (NEXIM, BOI,
FBMB,	NARFUND	-do-
BOA.
and IB)

The CBN has also noted the onerous challenge of having dedicated Compliance Officers (CO) at each branch of a bank and has given dispensation that banks may elect to operate a cluster structure, whereby a designated CO would be responsible for a cluster of branches instead of having a CO at each branch, as earlier advised in the circular under reference. Consequently, the CBN has approved the establishment of Zonal Compliance Officers for banks, who must at a minimum, be on the same level with the management of the Zones where they Branch /Cash Centres, therefore, need not have Compliance Officers, work.

provided the Compliance Officer at the Zone that controls the Branch/Cash Centre, effectively performs compliance functions at the Branch/Cash Centre, Where a bank or a financial institution decides to operate the cluster arrangement, details of such arrangement must be sent to the Director, Banking Supervision Department, or Director, Other Financial Institutions Department CBN, as the case may be, for prior approval.

The cluster structure must however take into cognisance, the size, number and proximity to each branch as well as the level of automation of the compliance function, without compromising compliance. It is important to note that, the function of Office(r) must be clearly separated from that of internal Compliance Control/Audit. Compliance Officers of Banks, Discount Houses and Other Financial Institutions should meet the criteria specified for the category of their institutions.

All banks and other financial institutions are hereby enjoined to comply strictly with the requirements of this circular.

KEVIN N. AMUGO DIRECTOR, FINANCIAL POLICY AND REGULATION DEPARTMENT