Compliance is at the heart of everything we do at SBS (ex-Sopra Banking Software). Behind all the products we sell to our customers, there are associated regulations. If our products are not compliant, service quality will be affected. It is therefore our responsibility to deliver products that comply with the requirements of the regulators (e.g. the Central Bank).
When the Central Bank shares a regulatory text that impacts banks’ information systems, it is Mounkaila Dia’s job to conduct studies to ensure that our customers are compliant.
A researcher at Cheikh Anta Diop University in Dakar, Mounkaila has always had a passion for research into the economy of the future. After 13 years working in the finance and regulatory sector, he joined SBS in 2022 as head of regulatory intelligence for the Middle East & Africa (MEA) region.
In this interview, Mounkaila talks about his passion for research and consultancy, his typical day and the challenge of becoming the “partner of choice” for regulatory authorities.
Why is regulatory monitoring essential to the SBS business?
Mounkaila DIA: We have regulatory maintenance contracts with our customers. We have to keep an eye on the regulations to be able to help our customers comply.
To give you an example, let’s suppose that the regulator today publishes a regulatory framework* on an aspect that it had identified in 2020. If it is published today and the date of enforcement is tomorrow, it is imperative that our customers are compliant by that date in order to avoid penalties from the regulator.
For this to be possible, we need to have taken steps to identify the issue as early as 2020, analysing, summarising and discussing it within a committee made up of key stakeholders. This monitoring enables us to meet the deadlines for our internal processes: identification, analysis, investment research, development work and delivery. Without regulatory monitoring, we would find it difficult to support our customers in achieving compliance.
In addition to this support, it’s also a question of providing a quality of service to our customers, to give the regulator a ‘Compliance’ vision.
*Regulatory framework = instruction, directive, regulation or law, etc.
How does your role fit into this compliance process?
Mounkaila DIA: My role involves researching, analysing and summarising, along with the regulators, all the regulatory aspects that have an impact on our customers’ information systems, in order to help them achieve compliance.
In concrete terms… Let’s say that the regulator shares the regulatory framework relating to the technical specifications for setting up a credit facility. This framework is set out in a document called a “regulatory instruction”.
I analyse this instruction to identify how it will impact the banks’ information systems. I then share my summary with the Offer department, which also analyses it before submitting it to R&D. If an investment decision is taken, the technical specifications are then developed by R&D and the compliant product is delivered to the customer in accordance with internal procedures.
What is your typical day ?
Mounkaila DIA: Recently I’ve been working on foreign exchange regulations, which impact the banks’ information systems,especially concerning transactions between WAEMU* countries and countries outside the WAEMU (e.g. transaction limits, currency allocation, import and export thresholds, etc.). This community regulation, applicable to the 8 countries of the Union, spans over 100 pages. Many of my colleagues, particularly in Supply and R&D, didn’t have enough time to read it in its entirety.
So my job was to summarise and analyse the text to help readers understand the regulations. I facilitate this process by translating the legal language (of the regulator) into simpler language to make it easier for stakeholders to understand and utilise.
So for the most part, a typical day consists in identifying and analysing regulatory texts, making it easier for users to read them, and requesting additional information from the regulator if everything is not clear to me from a legal point of view.
In addition to this work, I have regular exchanges with the regulator on the regulatory outlook and sometimes on technical questions asked by employees.
*WAEMU = West African Economic and Monetary Union
What challenges do you encounter in the course of your work?
Mounkaila DIA: Above all, delivery times. The challenge is to deliver to our customers before the date on which the regulations come into force (taking into account the tests to be carried out and the amendments that may be made at any time).
When the Central Bank issues a regulatory framework and asks banks to implement it within 10 days, I sometimes have to explain to the regulator that we don’t think this timeframe is feasible, given our experience of the same subject in other regulatory environments.
My role, at this stage, is to convince the regulator to revise the implementation date so that we are in a position to find the investments, carry out the approvals and conduct the regression tests (internal provisions).
What are the consequences if the delivery deadlines are not met?
Mounkaila DIA: If our delivery times do not coincide with the implementation of the regulatory instruction, then the bank is not compliant with the regulations. As a result, it is liable to sanctions from the regulator.
The other consequence is that the bank may decide to go to another competitor for a faster turnaround.
What are the future challenges of compliance?
Mounkaila DIA: Given the acceleration and innovation in the field of technology, the most important challenge is to be an “advisor and partner of choice” to the regulatory authorities in drawing up the regulatory frameworks governing activities in the financial sector.
What does it mean to be an “advisor and partner of choice”?
Mounkaila DIA: When the regulator puts in place regulatory texts, it needs to surround itself with advisers for certain technical aspects in order to facilitate the drafting of the regulatory framework.
Let’s take the example of a subject that is already in force in the European Union, such as Open Banking or the new liquidity standards (Basel 3) or IFRS. Let’s imagine that the regulator wants to implement it but doesn’t have enough technical tools to do so. As an advisor, it is in our interest to ‘advise’ them on a technical path by explaining what is already in force in other jurisdictions. Why should we do this? Because by giving our opinion, the regulatory authorities tend to give us greater visibility over their activities. And we win: the authorities have more confidence in us and let us take part in their decision-making committees.
For example, we are currently a member of a Central Bank of West African States technical committee called “CONOBAFI”, and others will follow in the next few days through the “OPEN BANKING” committee.
What do you enjoy most about being Compliance Manager?
Mounkaila DIA: What I enjoy most is the advice. And that’s linked to my passion for research and innovation in all areas of development economics. When I carry out research into regulatory law, I like to talk directly to the sales teams to explain the results of my research so that I can understand their perceptions and take them into account more effectively.
Another aspect I enjoy is making it easier for sales people to read the regulatory texts. I act as an intermediary if anything is unclear. I also help them to understand the law as it applies to the products they have to sell.
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