Over 70% of African Risk Managers are struggling to cope with Financial Crime Regulations and 24% admit they are “drowning”.

Earlier this year MoData sent out a survey to several hundred compliance and risk managers throughout Africa. Many of the results were quite unexpected including that almost a quarter of all respondents admitted to struggling to cope with both existing and new financial crime regulations. Approximately 50% reported that although they often got the budget they required – they did not get the support of senior management and the biggest obstacle was cultural change

The respondents were mainly in the Banking sector of the Financial Services Industry. There were few Insurance companies on the list for which we apologise. We will rectify this error later this year by having a specific Financial Crime Survey for the Insurance Industry (whose needs are similar but not exactly the same) and in 2020 combining the two surveys into one that covers the whole of the Financial Services Industry in Africa.

Over two hundred people responded to the survey, very few of whom were from Northern Africa (Egypt. Morocco, Algeria etc.) so it may be more appropriate to call this a report on a Financial Crime Survey of Sub-Saharan Africa. Those who responded were generally split three ways of around 1/3rd each namely; Strategic / C-Level, Operational and Managerial.

We especially asked respondents to indicate which region of Africa they operated in as we anticipated seeing some regional differences given the rise in activity in East Africa where the Reserve / Central Banks in Kenya and Tanzania been quite been quite voracious with imposing fines on banks there. Contrasting this we expected little new activity in South Africa as the large banks there generally say they have had systems in place for some time. But there were actually no anomalies or significant regional differences worthy of making note of.

Improving the efficiency and effectiveness of their Anti- Money Laundering (AML) monitoring programme was the most important activity for over half the respondents during the coming 18 months. It appears that everyone has an AML system but in the majority of cases it is inefficient and or not effective enough.

This is further reflected by the answers that nearly 30% of people said transaction monitoring was their main priority for the next year followed by PEP screening & sanctions at 11%

It will be interesting to observe how these priorities and initiatives evolve in the 2020 survey as the new forthcoming recommendations regarding Crypto-currencies, ultimate beneficial ownership and adoption of a risk-based approach come into effect.

The responses to the questions around finance and support were curious. Only 4% of those surveys reported that budgets were their biggest challenge and indeed the vast majority of respondents reported they were going to spend the same or slightly more than in previous year on financial crime with nearly a fifth saying they would spend significantly more meanwhile 7% % said that spending money on Financial Crime was not worth it

However, over 50% of respondents did not feel they were getting the support they needed from senior management. It appears that in Africa, upper management is prepared to sanction budget approval, particularly on new technology but they do so grudgingly. Introducing this new technology was marginally the overall leader as the forthcoming challenge facing one fifth (1/5th) of respondents which coupled with another 32% reporting equally a lack of culture or existing workload as their biggest challenges.

Only 2% felt they were “swimming in the fast lane” whilst 26% said they were keeping their head above water and were just about managing – however conversely 24% said they were drowning AND a whopping 48% declined to respond which some in the industry have interpreted as meaning that things are bad but they do not want to admit that they too are drowning – if this interpretation is correct then this means that over 70% of African Risk Managers are struggling to cope with Financial Crime Regulations (current and future) and yet a similar figure (70%) said that regulators were doing a good job and were either at best actively engaged with helping them or at least providing sufficient support.

Transaction monitoring scored the top marks for being the most important initiative for nearly thirty percent of Financial Institutions this year followed by KYC at almost twenty percent and PEP’s screening at just over ten percent. There were also some six different types of Fraud Initiative reported which individually were each quite small but combined would have placed Fraud just behind the leader Transaction Monitoring on twenty-six percent as the most important initiative

Reputational Damage was the biggest worry for a whopping two-thirds 2/3rds of Risk Managers – double that of Financial Loss, Loss of Data and Interruption of Service all put together.

To View all the results; – click on the link below and download the full report

For further information about this survey

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Risk Based Financial Crime Management Solutions


Martin Dolny

Director; Africa, UK & Europe

Tel South Africa +27 (0)79 697 1976

Tel UK +44 (0)779 500 6203

Email [email protected]

African Financial Crime Survey 2019 Report