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​​Financial institutions are responsible for establishing an organizational structure that embodies the requirements of good governance and includes functions that help to ensure proper, sound and prudent management. 


In this context, it is worth highlighting the essential functions included in the governance system, notably the risk management function, the compliance function and the internal audit function, in addition to others that Banco de Cabo Verde deems pertinent.

Key position (function) holders are subject to a suitability assessment and consequent special registration with Banco de Cabo Verde.

Type of legal act: Denial or acceptance.

Competent authority: Banco de Cabo Verde.

Applicable legislation: 
• Law on Financial Activities and Institutions (LAIF);
• Notice No. 4/2017, dated September 7 - Establishes the minimum requirements that a financial institution's internal control system must meet;
• Notice No. 1/2024, dated April 11 - Assessment of the Suitability and Registration of Key Functions.​

Checking the legal suitability requirements (good repute, qualifications and professional experience) of key position holders is primarily the responsibility of the supervised institution and, in the context of its supervisory duties, of Banco de Cabo Verde.

Banco de Cabo Verde's checking of key position holders' suitability has an eminently preventive function and aims to ensure that the holders provide assurances of sound and prudent management of the supervised institutions at all times.

However, Banco de Cabo Verde's suitability checks do not relieve the supervised institutions of their responsibilities. Supervised institutions have a legal obligation to ensure that the suitability requirements established by law are met on an ongoing basis, in accordance with Banco de Cabo Verde regulations. 

At publicly supported institutions, it is also the State's responsibility to ensure the people appointed to positions are assessed.

Selection and assessment policy and assessment report

Institutions must have a policy that clearly identifies the procedures to follow when initially and continuously selecting and assessing the suitability of key position holders, in accordance with the applicable legal requirements (good repute, qualifications and professional experience).

The results of the assessment of key position holders' suitability must be included in a report to be submitted to Banco de Cabo Verde as part of the special registration process for holding the position or whenever justified in the event of unforeseen circumstances.

Unforeseen circumstances

Financial institutions must, at any time, identify and report to Banco de Cabo Verde, as soon as they become aware of them, any unforeseen circumstances relating to the special registration for holding key positions which may affect the good repute, qualifications and professional experience requirements of key position holders.

Institutions must inform Banco de Cabo Verde of the measures they intend to take in the light of the unforeseen circumstances, in particular whether they intend to reassess the suitability of key position holders. In this case, they must also inform Banco de Cabo Verde of the result of the reassessment, submitting the corresponding reassessment report.


​The special registration process for holding key positions begins with the institution in question submitting an application to Banco de Cabo Verde. This application must be completed on a specific form and include the information and details referred to in Article 12 of Notice No. 1/2024, dated April 11. 


The institutions concerned must address their applications to Banco de Cabo Verde, Microprudential Supervision Department.

When the application or documentation submitted contains insufficient information or irregularities that can be remedied by the interested parties, the latter shall be notified to do so within a reasonable period of time, failing which the registration shall be denied.

Banco de Cabo Verde may request any information it deems necessary to properly process the application. The institution must submit them within any time limit set by Banco de Cabo Verde for this purpose, failing which registration will be denied for lack of information.

Banco de Cabo Verde has a period of 90 working days to decide on the suitability of the proposed key position holders. This period shall be interrupted whenever Banco de Cabo Verde requests information from the interested parties that it deems necessary to process the application, and shall start again upon receipt of said information.

​Once the formal process for the special registration of key position holders has been completed, Banco de Cabo Verde will carry out a substantive assessment of the proposed candidates, taking into account the following legal suitability requirements:


Good repute

Institutions are responsible for ensuring, at all times, that their key position holders are suitable to carry out their duties in the financial system.

For these purposes, good repute can be defined as good name / good reputation / good image, integrity or honesty: a person of good repute is a trustworthy person, i.e. a person who, from a third party's point of view, tends to adopt ethical behavior in their personal and professional life, in line with the sound and prudent management of a financial institution.

The behavior in question must indicate, in particular, that the person makes decisions in a thoughtful and judicious manner, that they meet their obligations on time and that they act, in general, in a way that is compatible with preserving market confidence.

The assessment of good repute is always an individual assessment, to which the principle of proportionality does not apply.

When assessing the good repute of a particular person, the institution must, based on the fullest possible information on the personal and professional conduct of the person being assessed, make a prognostic judgment as to their ability to ensure the sound and prudent management of the institution.

The prognostic judgment translates into a prudential risk analysis. To this end, the institution must collect the relevant evidence and assess its risk, in view of the likelihood that the person being assessed will adopt behaviors that do not ensure the sound and prudent management of the institution. If the institution considers that this possibility exists, based on concrete evidence, it should not consider that the good repute requirement has been met.

Key position holders are subject, mutatis mutandis, to the good repute requirements stipulated in the Law on Financial Activities and Institutions (LAIF) (Article 28) and Notice No. 4/2014, dated October 17 (as amended by Notice No. 4/2019, dated March 14) (Article 2), which list, in a non-exhaustive manner, evidence of a candidate's lack of good repute as a key position holder. 

The good repute requirement for a key position holder is deemed to be met if there is no evidence to suggest otherwise and no reason to doubt it. A key position holder is deemed not to meet the good repute requirement when their personal or professional conduct raises material doubts about their ability to ensure the sound and prudent management of the financial institution.

Qualifications and professional experience

With due regard for the principle of proportionality, institutions must ensure that key position holders have the necessary skills and qualifications to carry out their duties properly, thereby ensuring the sound and prudent management of the institution.

The qualifications and professional experience in question can be verified through academic qualifications or professional experience with a duration and responsibility that are in line with the characteristics, complexity and size of the institution, as well as the risks associated with its business.

The qualifications and professional experience requirements set out in Article 29 of the Law on Financial Activities and Institutions, in conjunction with Article 3 of Notice No. 4/2014, dated October 17 (as amended by Notice No. 4/2019, dated March 14) apply to key functions, mutatis mutandis).

Institutions must provide key position holders with internal or external training, as well as specific internationally recognized certification, to enable them to fill any gaps in knowledge and relevant skills and/or refresh them in the light of developments in matters relevant to the performance of their duties.​


Once the application has been processed, Banco de Cabo Verde notifies the financial institution of its decision to grant or deny special registration for holding a position, within 90 working days from the date of receipt of the duly completed application (subject to suspensions of the deadline).


Banco de Cabo Verde shall notify the interested parties and the financial institution of any denial of special registration to hold key positions on the grounds of lack of good repute, qualifications and professional experience, and shall comply with the rules on the preliminary hearing of interested parties.