What we are talking about
Regulatory training is training the company does not choose: a text requires it, a regulator can ask for proof of it, and its content changes when the text changes. It differs from development training, which the company organises freely.
In Morocco, the obligation does not come from a single text. It is spread across laws, sector circulars and guides published by the supervisory authorities. The main ones are summarised below, with a link to each source. The official texts are in French and Arabic.
What the texts say
| Area | Text | What it requires |
|---|---|---|
| Insurance | ACAPS circular no. AS/02/19 | Ongoing training for managers and staff, programmes evaluated regularly, awareness-raising at least once a year |
| Capital markets | AMMC practical guide on AML/CFT | Training suited to each role, an annual awareness campaign, training materials among the documents to keep |
| All AML/CFT obliged entities | Law no. 43-05 | An internal system for vigilance, detection, monitoring and risk management |
| Workplace safety | Labour Code, law no. 65-99 | Written communication, on hiring and at every change, of health, safety and risk-prevention provisions |
| Personal data | Law no. 09-08 | Technical and organisational security measures, processing on the controller’s instruction |
Insurance: the most precise text
ACAPS circular no. AS/02/19 of 25 September 2019 applies to insurance and reinsurance companies and to their intermediaries. Article 10 requires that the managers and staff concerned receive ongoing training, suited to the nature of their duties, and that training programmes be evaluated regularly. Article 11 provides for an awareness campaign at least once a year. Article 12 adds a check on the effectiveness of the training delivered, with the results reported to the governing bodies.
Banking
Credit institutions fall under law no. 43-05 and Bank Al-Maghrib circular no. 5/W/2017 on the duty of vigilance. We do not reproduce its articles here: your compliance function holds the text in force and its implementing letters, and it is for them to give you their reading of it.
Workplace safety and personal data
The Labour Code requires the employer to communicate in writing to employees, on hiring, the provisions on health, safety and risk prevention, and then every change made to them. Law no. 09-08, for its part, does not expressly require staff training. Article 23 requires organisational security measures, and article 25 that anyone acting under the controller’s authority processes data only on instruction. In practice, both requirements depend on an instruction that has been circulated and understood.
What the texts do not say
These texts have one thing in common: they set the obligation, not the proof. None of them imposes a tool or a format. The ACAPS circular, for example, does not expressly provide for keeping training records.
Proof becomes necessary indirectly, though. You cannot regularly evaluate a programme, check the effectiveness of training, or report to the governing bodies without knowing who took which content, on what date and with what result. And when the content has been revised in the meantime, you need to know which version you are talking about.
Three common difficulties
Intermediaries. Agents, brokers and distribution networks fall within the scope of the ACAPS circular, but usually have no account in the insurer’s LMS. Their training is tracked separately, when it is tracked at all.
Subsidiaries. Law no. 43-05 asks obliged entities to make sure their branches and subsidiaries abroad apply its provisions. Each entity often has its own LMS, and therefore its own copy of every module.
Revisions. Law no. 43-05 has been amended and supplemented since it was enacted, and the implementing circulars evolve. With every change, the module has to be updated everywhere, and the company has to be able to say who took the up-to-date version.
Where Sajay Dispatch fits
Sajay Dispatch does not produce your training and does not replace your LMS. It hosts each module once, serves it to all your LMSs and to your intermediaries by invitation, with no account to create, and records the version served, the learner and their result at every launch. You choose which version is in force and can go back to the previous one.
To go further: proving which version of a training course was taken.