Guinea-Bissau AML & Sanctions Compliance

Guinea-Bissau's AML/CFT regime is based on national laws and regional directives aimed at combating financial crime.

Guinea-Bissau's AML/CFT framework is primarily governed by its national Law on the Prevention and Suppression of Money Laundering and Terrorism Financing, and supporting regulations issued by:

• National Financial Information Unit (CNIF - Célula Nacional de Tratamento de Informação Financeira): Guinea-Bissau's FIU, responsible for STRs and financial intelligence.
• Central Bank of West African States (BCEAO): Regional central bank for WAEMU, issuing AML/CFT directives for financial institutions.
• Banking Commission of WAEMU: Regional banking supervisor ensuring compliance with AML/CFT obligations for credit institutions.
• National Agency for Financial Investigation (ANIF) & Insurance Regulators: ANIF conducts financial investigations. The insurance sector is also subject to AML/CFT oversight, often guided by regional UEMOA standards or specific national bodies.

FATF Status & Engagement

Summary of FATF Standing & Key Issues

Guinea-Bissau is a member of GIABA.

For detailed assessment information, refer to its Mutual Evaluation Report.

Key References/Verification

• GIABA
• FATF Consolidated Assessment Ratings

Core Obligations

• Customer Due Diligence (CDD) / Know Your Customer (KYC): Financial institutions must conduct risk-based customer due diligence. Enhanced due diligence required for high-risk customers, including PEPs, with particular attention to cross-border trade and cash transactions.
• Beneficial Ownership Identification: Requirements to identify and verify beneficial owners with a threshold of 25% ownership or effective control. Implementation has been strengthened with the creation of a beneficial ownership registry.
• Transaction Monitoring: Financial institutions must implement automated systems to detect suspicious transactions, with specific attention to cash transactions exceeding 5 million CFA francs.
• Record Keeping: Minimum 10-year retention period for all customer records and transactions, with specific requirements for high-risk customer documentation.
• Reporting Obligations: Suspicious Transaction Reports (STRs) must be filed with the FIU (CNIF) within 48 hours of detection. Cash Transaction Reports required for transactions exceeding 5 million CFA francs.

Key Challenges

• Maritime Sector Risks: Significant maritime activities and port operations create specific money laundering vulnerabilities, particularly in shipping and fishing sectors, requiring robust oversight.
• Cross-Border Trade & Cash Economy: Extensive cross-border trade, coupled with a significant cash-based economy, requires enhanced due diligence and sophisticated monitoring to mitigate illicit financial flows.
• Cashew Sector & Supply Chains: The large cashew sector with complex supply chains presents unique AML challenges, necessitating enhanced monitoring and due diligence procedures.
• Implementation & Resource Constraints: Inconsistent application of AML/CFT requirements and limited resources for supervision and enforcement pose ongoing challenges despite a strengthened legal framework.
• Informal Economy & Infrastructure: A large informal economy and limited digital/identification infrastructure hamper effective AML/CFT implementation, CDD, and transaction monitoring.