In this issue, discover the portrait of Mr. Serge HOUEDANOU, Secretary General of the financial intelligence unit (FIU) of Benin and OCWAR-M expert on the strengthening of financial institutions.
1/ Can you tell us about your professional background and your work at the Beninese FIU?
My professional career began in 1996 at the Central Bank of West African States (BCEAO), where I held various positions of responsibility before being seconded in 2017 to the Government of Benin as Representative of the BCEAO within the FIU, where I currently hold the position of Secretary General.
In this capacity, I am involved in all AML/CFT activities carried out by the FIU. In particular, I am in charge of the training and awareness raising of financial institutions regarding the implementation of their AML/CFT obligations.
My passion for AML/CFT led me to become ACAMS certified and to specialise in AML/CFT training. With these assets, I have taken on several important responsibilities at the national level, including:
- National Coordinator of the Committee in charge of the National Risk Assessment (NRA) of Benin;
- Coordinator of the Committee of national experts in charge of monitoring the Mutual Evaluation process of the AML/CFT framework in Benin;
- National Coordinator of the Committee for drafting the action plan for the implementation of the recommendations of the Mutual Evaluation Report (MER);
- National Coordinator of the Committee for the development of the national AML/CFT strategy.
At the sub-regional level, I was a member of the GIABA Risk Trend Methodology Group (RTMG) from 2017 to 2019 and since 2020, I am a member of the GIABA Policy Review Group. Furthermore, I participate on behalf of GIABA and as an Evaluator, in the mutual evaluation missions of the AML/CFT frameworks of the Member States.
In a nutshell, my background gives me a global vision as well as a proven knowledge and understanding of the AML/CFT challenges facing GIABA Member States, and UEMOA Member States in particular.
2/ You have worked with OCWAR-M as an expert on several activities to strengthen financial institutions; what are the stakes in strengthening these institutions with regard to AML/CFT?
Among the actors involved in AML/CFT, financial institutions occupy a central place, as they have ML/FT prevention obligations. It is therefore clear that strengthening the AML/CFT compliance mechanisms of these institutions is one of the major challenges of the OCWAR–M project. Indeed, financial institutions play a crucial role in preventing the abuse of financial systems for ML/FT purposes through the implementation of customer due diligence, record keeping and suspicious transaction reporting. The OCWAR–M project has therefore rightly set the objective of training the reporting entities and supervisors in this sector.
It is in this context that, thanks to Expertise France, I had the honour of putting my experience and knowledge at the service of the project on several AML/CFT capacity building activities for financial institutions in general and Decentralised Financial Systems in particular. Thus, thanks to the OCWAR–M project, practical training modules on the effective implementation of AML/CFT requirements have been developed and delivered to financial institutions and their supervisors in several ECOWAS countries. Given that AML/CFT preventive measures account for more than 40% of the FATF Recommendations, we understand the paramount stakes of capacity building in this sector.
3/ You also took part in a OCWAR-M training of trainers for the actors of the AML/CFT criminal chain, in relation to your functions at the FIU of Benin. In your opinion, what is the specificity of OCWAR-M’s actions, especially on these subjects in which you have been an actor and a beneficiary?
Indeed, as Secretary General of the FIU of Benin, I benefited from a training of trainers initiated by the OCWAR–M project for the actors of the penal chain.
First of all, allow me to confirm the accuracy of the diagnosis made by the project regarding the lack of training of the main actors in charge of the detection and repression of ML/FT in most countries of the sub-region.
Secondly, with regard to the proposed solution to this weakness, I very much welcome the ingenious idea of providing countries with a college of trainers on ML/FT detection, investigation and prosecution techniques and other specific related issues, including international mutual legal assistance, seizure and confiscation of assets.
This action illustrates one of the specificities that distinguishes the OCWAR–M project from other forms of capacity building and support: the project trains and provides each country with quality trainers to ensure the sustainability of the strengthening of national actors and this vision seems to me to be relevant and effective.
In view of the quality of the programmes of the various sessions and of the expertise of the instructors, this training course for investigators of financial intelligence units, magistrates, judicial police officers and asset management and recovery agencies, was a great success.