Preparing a suspicious transaction report for the CENTIF

The framework

In every WAEMU member state, the uniform law on combating money laundering and terrorist financing requires financial institutions to report to the national financial intelligence unit (CENTIF) the funds and operations they suspect come from an offence or are linked to terrorist financing. Money transfer and mobile money operators are subject to it, directly or through the licensed institution they operate for.

In Côte d’Ivoire, this uniform law is law n° 2016-992. Its article 79 gives the Minister of Finance the task of setting the reporting model: order n° 391 MEF/CENTIF of 30 October 2017, which describes a form in four parts. Each state sets its own model. As far as we know, only the Ivorian model is published; the other CENTIFs provide theirs on request.

When to report

The grounds listed on the Ivorian form give a good picture of the situations expected. They include:

• funds or operations suspected of coming from a crime or an offence, or from a predicate offence such as corruption, tax fraud or cybercrime;
• doubt about the identity of the originator, the beneficial owner or the person carrying out the operation;
• a link with a high-risk or non-cooperative jurisdiction;
• a person or entity subject to a freezing procedure, or funds subject to seizure or confiscation;
• split, repeated or structured operations, or operations backed by doubtful documents;
• operations the customer did not complete.

The form also covers operations that were not executed: attempted, still to be executed, refused by your institution or cancelled by the customer. A refused or abandoned operation can therefore be reported.

What the form contains

The Ivorian model has four parts, in this order:

1. Presentation: the reporting institution (address, post office box, city, e-mail, telephone) and your internal reference.
2. Detailed analysis: the nature of the suspicion (money laundering, terrorist financing or proliferation financing), the suspected predicate offences and the grounds for the report, chosen from the form’s list or described.
3. Indications: the status of the operations and its date, their place, their nature and the means used (cash, bank transfers, electronic transfers, electronic money, money transfer, crypto-assets, among others), and the reference and nature of the medium.
4. Identification: the natural and legal persons concerned.

The form ends with the place of signature and the name of the signatory. It also lists the attachments, such as customer due diligence documents and account statements.

Investigate before reporting

A sound report is built in a case, not directly in the form. Before you write:

1. Gather the related operations: those of the same sender, the same receiver, the same device or the same agent, over a period that covers the whole suspected pattern.
2. Establish the timeline: when the pattern starts, how it evolves, what revealed it.
3. Total the amounts per currency, without converting them: each amount must be traceable to its original operation.
4. Write the facts first, then the grounds: what you observed, then why it supports a suspicion. Describe operations, not people.
5. Record the measures taken: operation suspended or refused, relationship placed under watch, documents requested.
6. Have a second person review the case before filing, and keep a record of who decided what.

Mistakes that weaken a report

• Generic grounds, such as “unusual operation”, without the facts behind them.
• Operations listed without a date, an amount or a currency.
• Amounts converted and added up in a single currency, which can no longer be traced to the original operations.
• Incomplete identification of the persons, when the institution holds the documents.
• A report written long after the facts.
• No internal record of the decision: who investigated, who approved, when the report was filed and under which reference.

After filing

Keep the report as it was filed, with its date and the reference the CENTIF gave you. The customer remains under watch: new operations may call for a further report.

These records also feed the annual report that BCEAO Instruction 001-03-2025 requires of every financial institution: its article 12 provides for statistics on the implementation of the suspicious transaction reporting system.

What YARDA does, and what it does not do

In the YARDA console, an escalated alert opens a case that gathers the related operations, the timeline and the comments. The draft report is written there: suspected offence, grounds, facts, measures taken and operations with their totals per currency. The sections of the Ivorian form are then filled, with the list of mandatory entries still missing. When your policy requires it, a second person approves the report before it is filed, and the report is sealed with a SHA-256 fingerprint when you record its filing.

YARDA does not send anything to the CENTIF: filing remains an act of your institution. And because YARDA keeps only pseudonymised identifiers, your team completes the identification of the persons from its own records.