Rwanda AML & Sanctions Compliance

Rwanda's AML/CFT framework is primarily governed by Law N° 69/2018 of 31/08/2018 on prevention and punishment of money laundering, financing of terrorism and financing of proliferation of weapons of mass destruction. This is complemented by supporting regulations and directives issued by key national bodies, including:

• Financial Intelligence Centre (FIC): Rwanda's FIU, responsible for receiving, analyzing, and disseminating suspicious transaction reports (STRs) and other financial intelligence to combat ML/TF.
• National Bank of Rwanda (BNR): The central bank and primary financial sector regulator, responsible for issuing AML/CFT regulations, supervising banks, microfinance institutions, insurance companies, and payment service providers.
• Rwanda Revenue Authority (RRA): Plays a role in monitoring cross-border currency movements and investigating tax-related financial crimes.
• Rwanda Investigation Bureau (RIB): The primary law enforcement agency responsible for investigating complex financial crimes, including money laundering and terrorism financing.

FATF Status & Engagement

Summary of FATF Standing & Key Issues

Key References/Verification

• FATF MER of Rwanda 2023
• ESAAMLG
• FATF Consolidated Assessment Ratings

Core Obligations

• Customer Due Diligence (CDD) / Know Your Customer (KYC): Institutions must identify and verify the identity of their customers and beneficial owners using reliable, independent source documents (e.g., National ID for residents, passports for non-residents). Risk-based CDD is essential, with enhanced due diligence (EDD) for higher-risk customers, including PEPs, and for complex or unusually large transactions, especially those involving cross-border elements or new technologies.
• Beneficial Ownership Identification: Robust measures are required to identify and take reasonable measures to verify the identity of beneficial owners, typically applying a threshold of 25% ownership or effective control. Rwanda has established a beneficial ownership registry.
• Transaction Monitoring: Financial institutions must implement systems to monitor customer transactions and detect those that are unusual, complex, or potentially suspicious, paying particular attention to transactions linked to high-risk sectors (e.g., minerals trade) or jurisdictions, and those conducted through digital channels.
• Record Keeping: All customer identification data, transaction records, and related documentation (including STR filings) must be maintained for at least ten years after the business relationship ends or the transaction is completed.
• Reporting Obligations: Suspicious Transaction Reports (STRs) must be filed promptly with the FIC (e.g., within 24 hours of forming a suspicion). Cash Transaction Reports (CTRs) are also required for transactions exceeding a specified threshold (e.g., RWF 10 million or its equivalent in foreign currency).

Key Challenges (Compliance Context)

• Rapid Growth in Digital Financial Services: The fast expansion of mobile money and fintech solutions necessitates agile AML/CFT controls, robust e-KYC, and effective monitoring of digital transaction typologies.
• Cross-Border Trade & Regional Integration: Significant trade with neighboring countries, particularly within the EAC, requires enhanced due diligence on cross-border transactions and counterparties to mitigate risks of TBML and illicit flows.
• Minerals Trade & Traceability: The trade in minerals (e.g., gold, coltan) presents inherent ML/TF risks due to potential links to conflict financing and smuggling, demanding stringent supply chain due diligence.
• Ensuring BO Transparency: Despite a BO registry, ensuring the accuracy, timeliness, and verification of beneficial ownership information, especially for complex legal structures and foreign-owned entities, remains an ongoing focus.
• Capacity Building & Awareness: Continuous capacity building for both regulatory staff and reporting entities is crucial to keep pace with evolving ML/TF typologies and ensure effective implementation of AML/CFT measures.