AML/CFT in the WAEMU, seen from a transfer operator

The players

• The FATF sets the international standards for combating money laundering and terrorist financing.
• GIABA, the FATF-style regional body for West Africa, assesses how each state implements these standards.
• The WAEMU adopted a uniform law on combating money laundering and terrorist financing, which each member state has transposed; in Côte d’Ivoire, it is law n° 2016-992.
• The BCEAO sets out, through its instructions, the obligations of financial institutions, in particular their internal system and customer due diligence.
• The CENTIF, the national financial intelligence unit, receives suspicious transaction reports in each state.
• The supervisory authority your institution reports to checks that your system works and receives your annual report.

Knowing customers and rating risks

BCEAO Instruction 003-03-2025 of 19 March 2025 covers identification, identity verification and customer due diligence. Its article 25 requires each business relationship to be rated by risk, and its article 26 governs how risk factors are weighted. Weightings must not be excessively influenced by a single factor, nor by economic or profit considerations, and must not make it impossible to rate a relationship or a transaction as high risk.

Monitoring operations

BCEAO Instruction 001-03-2025 of 18 March 2025 expects the financial institution, in its article 6, to have an information system that allows, among other things, customer profiling, real-time filtering, the monitoring of movements, the generation of alerts, the census of a customer’s operations and the identification of suspicious or unusual transactions. Its effectiveness must be examined periodically, at least once a year; article 8 gives that examination to the internal AML/CFT unit.

Reporting to the CENTIF

Funds and operations suspected of coming from an offence or being linked to terrorist financing are reported to the CENTIF, on the model set in each state. The texts forbid informing the customer. Our guide on the suspicious transaction report details the CENTIF Côte d’Ivoire form and how to investigate a case.

Applying targeted financial sanctions

Persons and entities designated by the United Nations Security Council, and those each state lists nationally under resolution 1373, are subject to freezing measures. Your customers must be screened against these lists, and screened again when the lists change, within the time set by the texts that apply to your institution. Freezing assets and reporting remain acts of the institution.

Keeping records

Documents and operation data are kept for at least ten years. A longer period may be chosen; a shorter one, never.

Reporting every year

Article 12 of Instruction 001-03-2025 requires an annual report on the implementation of the internal AML/CFT system, sent to the BCEAO and to the supervisory authority within two months of the end of the financial year. It covers eight points, among them organisation and means, training, controls, statistics on the suspicious transaction reporting system and a map of the most common suspicious operations, with how they changed.

What a tool like YARDA covers, and what it does not

YARDA takes on part of the information system described in article 6: the analysis of every operation, alerts, cases, the preparation of reports, the facts of the yearly examination for the part it runs, the figures for two of the eight points of the annual report, and screening against the United Nations list and the national list of Côte d’Ivoire.

What remains with the institution: verifying its customers’ identities, rating its business relationships, assessing politically exposed persons, training, internal control, freezing assets, filing reports and writing the other six points of the annual report.