What has happened?

The African Continental Free Trade Area (“AfCFTA”) has emerged as a pivotal opportunity that will set the framework for future trade across Africa. Amid the prospects, one of the challenges has been the fragmented and diverse regulatory environment, coupled with regulators adopting policies that are not conducive for multinationals to make investments and operate efficiently across Africa.

Following protracted negotiations, and industry consultations, the 37th African Union (“AU”) Heads of States Summit held on 17 – 18 February 2024, adopted the much anticipated AfCFTA Protocol on Digital Trade (“AfCFTA Digital Protocol”).

The AfCFTA Digital Protocol establishes an important legal instrument that will, through harmonized rules and common principles and standards, support and enable an acceleration of technology driven innovation and commerce in Africa. It focuses on promoting intra-African digital trade, enhancing cooperation on digital matters among State Parties, and creating a transparent, secure, and trusted digital trade ecosystem.

Why is this development important for technology companies operating in Africa?

The AfCFTA Digital Protocol covers important areas such as data governance, data protection, cross-border data flows, online consumer protection, cybersecurity and emerging technologies (including artificial intelligence). For multinational technology companies, that operate in several jurisdictions across Africa, this is particularly important given the historic and current challenges relating to limited regulatory and commercial inter-operability between jurisdictions, the high cost of compliance and transaction costs, and limited access to regional markets.

How can we help?

It is essential for multinational companies, to continue to engage regulators as the AfCFTA Digital Protocol enters into force. While the framework has been set out, it is expected that several annexures will be developed over the next few years, to give effect to the overall framework.

The Covington team has worked closely with the AfCFTA Secretariat, various African governments and leading multinational and African technology companies, contributing substantively to the development of the AfCFTA Digital Protocol as adopted by the AU Heads of States. Our team remains available to businesses as they navigate the AfCFTA Digital Protocol, particularly as it affects products and services offered at an individual company level.

Our team would be happy to address any questions you may have.

Photo of Mosa Mkhize Mosa Mkhize

Mosa Mkhize is a policy advisor and leads the firm’s Africa Public Policy Practice. Drawing on her experience both in government and in various roles in the private sector, Mosa provides strategic policy and regulatory advice to clients doing business with and across…

Mosa Mkhize is a policy advisor and leads the firm’s Africa Public Policy Practice. Drawing on her experience both in government and in various roles in the private sector, Mosa provides strategic policy and regulatory advice to clients doing business with and across Africa. Mosa does so by leveraging close to two decades of experience in international trade, public policy and government affairs.

Mosa assists clients on a broad range of issues including advocacy, strategic policy, regulatory, and dispute resolution advice in various sectors, including technology, energy and life sciences. In addition to this, Mosa’s capabilities include building strategic relationships and coalitions in support of smart technologies. Furthermore, she is currently working with government officials, private corporations, academia, and the general public on the development of regulations and policies that will bring about an enabling environment for digital transformation and economic growth in Africa.

Photo of Benjamin Haley Benjamin Haley

Ben Haley leads the firm’s White Collar and Anti-Corruption Practice in the Middle East and Africa and is a chair of the firm’s broader Africa Practice. With deep experience representing clients before regulators in high-profile white collar and disputes matters and a history operating on…

Ben Haley leads the firm’s White Collar and Anti-Corruption Practice in the Middle East and Africa and is a chair of the firm’s broader Africa Practice. With deep experience representing clients before regulators in high-profile white collar and disputes matters and a history operating on the ground in emerging markets, he helps clients assess and mitigate a wide range of complex legal and compliance risks.

Complementing his investigations and dispute resolution practice, Ben has a broad-based compliance advisory practice, helping clients proactively manage compliance risk in areas including anti-corruption, trade controls, anti-money laundering, fraud, and data privacy.

Ben represents corporate and individuals clients in a wide range of investigations and disputes, including:

  • Investigations under the U.S. Foreign Corrupt Practices Act (“FCPA”).
  • Investigations into anti-money laundering, financial crimes, anti-terrorism, and sanctions and export control issues.
  • Securities fraud and accounting matters.
  • Board investigations and shareholder litigation.
  • Insurance recovery.

Ben also regularly advises clients on a range of regulatory compliance and corporate governance issues. His compliance advisory practice includes:

  • Performing risk and compliance program assessments.
  • Leading compliance reviews on business partners and assisting companies with third-party risk management processes.
  • Conducting forensic accounting reviews and testing and enhancing financial controls.
  • Advising on market entry, cross-border transactions, and pre-acquisition diligence and post-acquisition integration.
  • Assisting companies in designing, implementing, and maintaining best-in-class compliance programs.

In recent years, Ben has steered a number of clients to successful resolutions and declinations in complex FCPA and corporate fraud matters with the U.S. Department of Justice and Securities Exchange Commission. In his advisory practice, Ben has served as lead compliance counsel on a number of major M&A and investment transactions. He has developed special expertise assisting clients in leveraging technology in their compliance programs, including assisting one of the world’s largest consumer goods companies in the design and implementation of an award-winning compliance data analytics and monitoring system.

Ben has been described by the Chief Compliance Officer of one of his clients as “[a]n outstanding senior lawyer and advisor,” and “a guiding light for all things compliance advisory in Africa,” whose “advice is crystal clear, covers all angles and is business friendly.”

Photo of Deon Govender Deon Govender

Deon Govender is a vice chair of the Africa Practice Group. He focuses his practice on project development and corporate and project finance transactions across Africa, with particular emphasis on southern Africa. His experience ranges from advising on the development and financing of…

Deon Govender is a vice chair of the Africa Practice Group. He focuses his practice on project development and corporate and project finance transactions across Africa, with particular emphasis on southern Africa. His experience ranges from advising on the development and financing of renewable energy and thermal power projects and various other infrastructure assets in the transportation and telecommunications sectors. Deon’s experience additionally includes advising on financing independent power producer projects under the South African government’s Renewable Energy Independent Power Producer Procurement Programme.

Photo of Ahmed Mokdad Ahmed Mokdad

Ahmed Mokdad is an associate based in the Johannesburg office, and a member of the firm’s White Collar Defense and Investigations and Anti-Corruption Practice Groups, as well as the Privacy and Cyber Security Practice Group. With a depth of experience representing clients across…

Ahmed Mokdad is an associate based in the Johannesburg office, and a member of the firm’s White Collar Defense and Investigations and Anti-Corruption Practice Groups, as well as the Privacy and Cyber Security Practice Group. With a depth of experience representing clients across various sectors, Ahmed regularly assists clients navigate and mitigate a broad spectrum of regulatory and compliance risks.

Ahmed’s investigations practice includes internal and government investigations into anti-corruption, anti-money laundering, fraud, and financial crimes matters more generally. Complementing his investigations practice, Ahmed has a broad-based compliance advisory practice in these areas and in data protection and information security matters. This includes assisting clients in numerous sectors with compliance under South Africa’s Protection of Personal Information Act (POPIA).

Adding to his investigative, regulatory and compliance advisory experience, Ahmed has extensive experience advising on numerous M&A and complex financial transactions. He has also been involved in several high profile international arbitrations, and litigious matters before the South African courts relating to, among other things, commercial and tax disputes, exchange control violations, government procurement irregularities, and defending white collar crimes. This experience gives Ahmed valuable perspectives and insights when advising on compliance advisory matters.

For international clients facing compliance issues cutting into Africa, Ahmed regularly advises on a range of issues that can arise in such context, e.g., labor and employment considerations, legal professional privilege, whistleblower protections, corporate governance reporting obligations, and control processes and protocols for engaging with government and law enforcement agencies. Ahmed is recognized by clients for providing practical advice and solutions on complex legal issues in ambiguous statutory regimes.