Democratic Republic of Congo AML & Sanctions Compliance - ANQA

Democratic Republic of Congo AML & Sanctions Compliance

Navigate the challenging regulatory landscape of AML and sanctions compliance in the DRC with Anqa's country-specific solutions.

Democratic Republic of Congo Overview

The Democratic Republic of Congo (DRC) faces significant challenges in implementing an effective AML/CFT regime due to limited resources, governance challenges, and ongoing conflicts in parts of the country. The country's AML/CFT framework has substantial technical deficiencies and implementation effectiveness issues, despite being a member of the Task Force on Money Laundering in Central Africa (GABAC).

Regulatory Framework

Key Legislation & Authorities

The DRC's AML/CFT framework is primarily governed by Law No. 04/016 of July 19, 2004, on Anti-Money Laundering and Counter-Terrorism Financing, as amended by Law No. 16/002 of 2016. Key regulatory and supervisory bodies include:

  • National Financial Intelligence Unit (CENAREF - Cellule Nationale des Renseignements Financiers): The FIU of the DRC.
  • Central Bank of Congo (BCC - Banque Centrale du Congo): The banking supervisor.
  • Task Force on Money Laundering in Central Africa (GABAC): The regional FATF-Style Regional Body (FSRB) of which DRC is a member.
  • Insurance Regulation and Control Authority (ARCA - Autorité de Régulation et de Contrôle des Assurances): The insurance sector regulator.

FATF Status & Engagement

Summary of FATF Standing & Key Issues

Key References/Verification

Compliance Requirements

Financial institutions and Designated Non-Financial Businesses and Professions (DNFBPs) in the DRC must implement AML/CFT measures aligned with national laws and GABAC directives to prevent financial system misuse.

Core Obligations

  • CDD/KYC: Financial institutions must conduct risk-based customer due diligence. Enhanced due diligence (EDD) is required for high-risk customers, including Politically Exposed Persons (PEPs), and for transactions linked to high-risk sectors like mining and cross-border trade.
  • Beneficial Ownership: Entities must identify and take reasonable measures to verify beneficial owners (typically 25% threshold or control). Improving BO transparency is a key focus area.
  • Transaction Monitoring: Implement systems to detect suspicious transactions, with specific attention to mining-related payments (e.g., above 5 million CDF), large cash transactions, and activities in conflict-affected areas.
  • Record Keeping: Maintain all CDD records, transaction details, and related correspondence for a minimum of 10 years after the business relationship ends or transaction is completed.
  • Reporting: File Suspicious Transaction Reports (STRs/DDS) with CENAREF promptly. Cash Transaction Reports (CTRs/DO) for transactions exceeding legal thresholds are also required.

Key Challenges (Operational)

  • Mining Sector & Natural Resources: Significant ML/TF risks associated with the exploitation and trade of natural resources (gold, diamonds, coltan), often linked to informal and illicit activities.
  • Conflict Zones & Instability: Ongoing conflicts in eastern DRC hinder AML/CFT implementation and facilitate illicit financial flows, including TF.
  • Cash-Based & Dual Currency Economy: High prevalence of cash transactions (both CDF and USD) complicates traceability and monitoring.
  • Limited Infrastructure & ID Systems: Weak identification systems and limited digital/financial infrastructure hamper effective CDD and monitoring.
  • Corruption & Governance: High levels of corruption and governance challenges undermine AML/CFT efforts and increase risks associated with PEPs.

Sanctions Considerations

The DRC is obligated to implement UN Security Council sanctions, including those related to arms embargoes, asset freezes, and travel bans on designated individuals and entities, particularly those involved in fueling conflict or illicitly exploiting natural resources. Financial institutions and DNFBPs must screen customers and transactions against relevant UN sanctions lists.

Compliance programs should include procedures for identifying and freezing assets of designated persons/entities without delay and reporting actions to competent authorities. Given the FATF's focus on improving TFS implementation, this is a critical area for DRC entities.

Key Compliance Challenges in the DRC

Navigating the specific AML/CFT obstacles in the DRC's operating environment.

1

Resource Exploitation & Illicit Trade

Significant illegal mining and natural resource exploitation create major ML/TF vulnerabilities, particularly in the artisanal mining sector and cross-border trade of high-value minerals.

2

Conflict Financing & Instability

Ongoing conflicts in eastern regions complicate AML controls and create unique challenges for identifying and disrupting TF channels.

3

Beneficial Ownership Transparency

Ensuring accurate and timely identification and verification of beneficial owners, especially for companies in the extractive sector, is a critical FATF focus area.

4

Supervisory Capacity & Enforcement

Strengthening risk-based supervision by CENAREF, BCC, and other authorities, and improving the capacity for effective ML/TF investigations and prosecutions.

5

Cash-Based & Dual Currency Issues

The widespread use of cash (CDF and USD) and informal financial systems complicates transaction monitoring and CDD application.

6

Targeted Financial Sanctions (TFS)

Effectively implementing UN targeted financial sanctions related to TF and PF, a key component of DRC's FATF action plan.

Anqa's Tailored Approach for the DRC

Our solutions are designed to address the DRC's specific AML/CFT challenges and regulatory requirements, aligning with Law 04/016 and GABAC/FATF recommendations.

1

GABAC/FATF-Aligned Risk Profiling

Customer risk assessment tools incorporating GABAC/FATF findings and NRA priorities for the DRC, focusing on mining, conflict zones, PEPs, and cross-border activities.

Benefit: Precise risk categorization to meet FATF action plan items and local ML/TF typologies.

2

EDD for Mining & High-Risk Sectors

Workflows for EDD on entities in mining and other high-risk sectors, including BO verification, SOW/SOF analysis, and conflict minerals due diligence support.

Benefit: Robust compliance for sectors highly vulnerable to financial crime, supporting national efforts.

3

Comprehensive Watchlist & TFS Screening

Real-time screening against UN sanctions (especially DRC-specific regimes), GABAC lists, plus specialized TF/PF watchlists. Supports effective TFS implementation.

Benefit: Addresses a key FATF strategic deficiency by strengthening TFS implementation.

4

Dual Currency Transaction Monitoring

AI-driven monitoring with scenarios tailored for DRC's dual currency (CDF/USD) environment, detecting unusual cash flows and transactions linked to conflict zones or illicit mining.

Benefit: Supports CENAREF reporting and addresses critical ML/TF risks specific to the DRC.

5

BO Management & Verification Aids

Tools to assist in collecting, verifying, and maintaining beneficial ownership information, crucial for FATF compliance and enhancing transparency in high-risk sectors.

Benefit: Aids in meeting transparency obligations on BO, a critical FATF action point.

6

Regulatory Reporting for CENAREF

Streamlined generation of STRs and CTRs in formats compliant with CENAREF requirements, improving accuracy and efficiency in reporting to the FIU.

Benefit: Ensures timely and accurate reporting, supporting national AML/CFT efforts.

Anqa: Partnering for AML/CFT Excellence in the DRC

Anqa is committed to empowering financial institutions and DNFBPs in the DRC to achieve the highest standards of AML/CFT compliance. Our solutions are designed to meet current regulatory requirements set by CENAREF, BCC, and in alignment with GABAC/FATF recommendations for the DRC, and to anticipate future challenges in this complex market.

We provide robust, adaptable tools for effective risk management, streamlined compliance, and support for the DRC's efforts against financial crime and in addressing its FATF action plan. Partner with Anqa to build a resilient compliance framework that protects your institution and contributes to the integrity of the DRC's financial system.

Democratic Republic of Congo (DRC) — AML & Compliance FAQs

  • AML compliance in the DRC is regulated by the Cellule Nationale des Renseignements Financiers (CENAREF). CENAREF oversees anti-money laundering (AML) and counter-financing of terrorism (CFT) regulations for financial institutions, fintechs, and designated non-financial businesses under the national DRC AML compliance framework established by Law No. 04/016.

  • Businesses operating in the DRC must implement robust customer due diligence (CDD) policies, monitor transactions for suspicious activities, maintain accurate transaction records, and file Suspicious Transaction Reports (STRs) with CENAREF. Understanding the KYC obligations in DRC and following proper CENAREF STR filing procedures are critical for achieving and maintaining full DRC AML compliance.

  • An STR must be filed with CENAREF when there are reasonable grounds to suspect money laundering, terrorism financing, or other financial crimes. Prompt reporting through the appropriate CENAREF STR filing procedures is essential for maintaining DRC AML compliance and for assisting national authorities in combatting illicit financial flows.

  • Yes. Fintech companies, mobile money operators, and digital finance providers are fully subject to DRC AML compliance obligations. They must implement strong KYC verification systems, monitor transactions continuously, and file STRs in line with mobile finance AML regulations DRC, ensuring alignment with national financial crime prevention goals.

  • Anqa Compliance offers tailored, mobile-friendly compliance solutions designed to help businesses in the DRC meet evolving AML/CFT requirements. Our platform streamlines KYC onboarding according to KYC obligations in DRC, automates transaction monitoring, and facilitates fast, accurate STR reporting to CENAREF — supporting seamless DRC AML compliance at scale.

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