Senegal AML & Sanctions Compliance - ANQA

Senegal AML & Sanctions Compliance

Navigate Senegal's evolving financial regulatory landscape with Anqa's comprehensive compliance solutions designed for West Africa's emerging financial sector.

Senegal Overview

Senegal has significantly strengthened its AML/CFT framework, leading to its removal from the FATF's grey list. The Central Bank of West African States (BCEAO) and the National Financial Information Processing Unit (CENTIF-Senegal) are key regulators. Senegal is an active member of GIABA and continues to enhance its compliance regime.

Regulatory Framework

Senegal's approach to Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) is anchored by a framework of national laws and regional directives. This framework establishes the legal and operational mechanisms for preventing, detecting, and prosecuting financial crimes.

The AML/CFT framework in Senegal is primarily governed by Law No. 2018-03 of February 23, 2018, on Combating Money Laundering and Terrorist Financing. This is complemented by supporting regulations and directives issued by key national and regional bodies, including:

  • National Financial Information Processing Unit (CENTIF-Senegal): Senegal's Financial Intelligence Unit (FIU), responsible for receiving, analyzing, and disseminating suspicious transaction reports (STRs) and other financial intelligence.
  • Central Bank of West African States (BCEAO): The regional central bank for WAEMU (West African Economic and Monetary Union) member states, including Senegal. It issues prudential regulations and AML/CFT directives applicable to banks and financial institutions.
  • Banking Commission of WAEMU: The regional banking supervisor, responsible for the oversight and control of credit institutions within WAEMU, ensuring compliance with banking regulations, including AML/CFT obligations.
  • Insurance Control Commission (CAC - Conférence Interafricaine des Marchés d'Assurances - CIMA): While CIMA is the regional body, Senegal has national structures that enforce CIMA's insurance code, which includes AML/CFT provisions for the insurance sector.

FATF Status & Engagement

Summary of FATF Standing & Key Issues

Key References/Verification

Compliance Requirements

Financial institutions and Designated Non-Financial Businesses and Professions (DNFBPs) operating in Senegal are mandated to implement a range of AML/CFT measures in line with Law No. 2018-03 and relevant BCEAO/WAEMU directives. These measures are designed to prevent the misuse of the financial system for money laundering or terrorist financing.

Core Obligations

  • Customer Due Diligence (CDD) / Know Your Customer (KYC): Institutions must conduct risk-based customer due diligence. Enhanced due diligence (EDD) is required for higher-risk customers, including Politically Exposed Persons (PEPs), with particular attention to port operations, cross-border trade, and free trade zones.
  • Beneficial Ownership Identification: Requirements to identify and verify beneficial owners, typically applying 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 systems, often automated, to detect suspicious transactions, with specific attention to port-related payments exceeding established thresholds (e.g., 5 million CFA francs).
  • Record Keeping: A minimum 10-year retention period is required for all customer identification data, transaction records, and related documentation, with specific requirements for port-related documentation and free trade zone transactions.
  • Reporting Obligations: Suspicious Transaction Reports (STRs) must be filed promptly with CENTIF-Senegal (e.g., within 48 hours of forming a suspicion). Cash Transaction Reports (CTRs) are also required for transactions exceeding a specified threshold (e.g., 5 million CFA francs).

Key Challenges

  • Port Operations and Trade-Based Money Laundering: The significant volume of activity through the Port of Dakar and extensive cross-border trade create vulnerabilities for trade-based money laundering and illicit financial flows.
  • Informal Economy and Cash Usage: A large informal sector and high prevalence of cash transactions complicate the traceability of funds and the effective implementation of AML/CFT measures, particularly in cross-border trade.
  • Free Trade Zones (FTZs) and Special Economic Zones: While promoting economic activity, FTZs can present higher ML/TF risks if not adequately supervised, requiring specific monitoring of business activities and financial flows.
  • Consistent Application and Supervision: Ensuring consistent application of AML/CFT requirements across all financial sectors and effective supervision remains an ongoing focus.
  • Emerging Digital Financial Services: The rapid growth of mobile money and other digital financial services introduces new ML/TF typologies that require adaptive regulatory responses and enhanced monitoring.

Sanctions Considerations

Senegal, as a member of the United Nations, is obligated to implement UN Security Council Resolutions (UNSCRs) related to targeted financial sanctions. This implementation occurs through national laws and regional (WAEMU/BCEAO) directives. Financial institutions and DNFBPs must screen their customers and transactions against UN sanctions lists and any other applicable national or regional lists. Vigilance is crucial for transactions linked to port operations, cross-border trade, and free trade zones.

Enhanced due diligence should be applied to transactions involving entities or individuals from or connected to jurisdictions identified by the FATF as high-risk or under increased monitoring (even if Senegal itself is not listed), as well as those associated with PEPs and state-owned enterprises, especially in sectors vulnerable to financial crime.

Key Compliance Challenges in Senegal

Understanding the unique obstacles facing financial institutions and DNFBPs in Senegal

1

Port Operations & Illicit Trade

Complex port operations (e.g., Port of Dakar) and related financial flows create specific money laundering vulnerabilities, requiring enhanced monitoring of maritime transactions and port-related payments to detect potential trade-based money laundering.

2

Cross-Border Cash & Informal Flows

Extensive informal cross-border trade, often cash-intensive, requires sophisticated monitoring systems and enhanced due diligence, particularly with neighboring countries, to identify illicit financial flows within the WAEMU region.

3

Free Trade & Special Economic Zone Oversight

Multiple free trade zones and special economic zones require enhanced monitoring of business activities and financial flows, with specific attention to commercial operations to prevent misuse for illicit purposes.

4

Effective Beneficial Ownership Transparency

Ensuring accurate and timely identification and verification of beneficial owners, especially for complex legal structures or those operating across WAEMU borders, remains a key focus despite the establishment of a registry.

5

Digital Finance Risk Management

Rapid growth of mobile money and digital financial services requires enhanced monitoring, robust KYC for remote onboarding, and sophisticated risk management strategies to address new ML/TF typologies in line with BCEAO guidelines.

6

Resource & Capacity Building

Continued need for capacity building and resource allocation for both supervision and within reporting entities to ensure robust implementation and adherence to the strengthened legal framework (Law No. 2018-03).

Anqa's Approach for Senegal: The Platform

Our comprehensive AML solution tailored for Senegal's unique regulatory landscape, incorporating Law No. 2018-03, CENTIF-Senegal guidelines, and WAEMU regional standards.

1

Senegal KYC/CDD & Onboarding Hub

Streamlined digital onboarding with selfie biometric verification, liveness detection, and secure document vault. Configurable workflows align with Senegal's specific CDD requirements under Law No. 2018-03, catering to individuals, SMEs, and corporates, including entities in port operations and FTZs.

Benefit: Ensures tailored CDD for high-risk port and FTZ entities, aligns with Senegalese Law No. 2018-03 and CENTIF-Senegal expectations, streamlining compliance for specialized sectors.

2

Risk-Based Approach for Senegal

Dynamic risk scoring engine assessing customer profiles, transaction patterns, beneficial ownership structures, and geographical factors. Customizable risk parameters address Senegal's specific vulnerabilities like port activities (Port of Dakar), cross-border trade (WAEMU nuances), and cash-intensive sectors.

Benefit: Provides granular risk insights for Senegal's maritime and trade finance sectors, enabling targeted EDD and resource allocation as per GIABA recommendations.

3

Comprehensive Screening (WAEMU Focus)

Real-time screening against UN, OFAC, EU, and other global sanctions lists, PEP databases, and adverse media. Includes specific focus on WAEMU regional lists and allows for custom internal watchlist integration, crucial for entities in Senegal.

Benefit: Facilitates robust compliance with Senegalese and WAEMU sanctions regimes, minimizing exposure to sanctioned entities in critical trade and port operations.

4

Transaction Monitoring (XOF & Digital)

Advanced transaction monitoring with scenario-based rules and anomaly detection, tailored for XOF (CFA Franc) transactions, mobile money operations, and digital financial services prevalent in Senegal. Supports CTR generation for CENTIF-Senegal.

Benefit: Addresses emerging ML/TF risks in Senegal's growing digital payments ecosystem, supporting compliance with BCEAO directives for mobile money and fintech.

5

Audit Trail & Regulatory Reporting

Immutable audit logs for all compliance activities. Streamlined case management and reporting tools, with templates adaptable for CENTIF-Senegal submissions and BCEAO/WAEMU oversight requirements for Senegalese institutions.

Benefit: Enhances oversight of WAEMU-wide transactions originating from or passing through Senegal, supporting efforts against regional illicit financial flows.

6

Localized for Senegal (French Language & Support)

Platform interface and support available in French. Flexible deployment (cloud/on-premise) to suit Senegal's infrastructure. Training and support geared towards local teams and regulatory understanding (Law No. 2018-03, CENTIF-Senegal processes).

Benefit: Offers a flexible, French-supported AML solution adaptable to Senegalese infrastructure, promoting wider adoption and effective compliance management.

Anqa: Partnering for AML/CFT Excellence in Senegal

Anqa is dedicated to bolstering Senegal's commitment to a robust AML/CFT framework, particularly following its successful exit from the FATF grey list. Our platform empowers Senegalese NBFIs and DNFBPs to meet the stringent requirements of Law No. 2018-03 and CENTIF-Senegal directives, focusing on key areas like port operations, cross-border trade, and the burgeoning digital finance sector.

By providing advanced, localized compliance tools, Anqa supports Senegal's ongoing efforts to maintain international AML/CFT standards, foster financial integrity, and attract sustainable investment, contributing to the nation's economic resilience and its respected position within GIABA and the WAEMU region.

Senegal — AML & Compliance FAQs

  • Financial institutions must conduct KYC, assess customer risk, report suspicious transactions, and maintain records — in compliance with laws enforced by CENTIF-Sénégal.

  • Yes. Insurers and telecoms are classified as reporting entities and must implement risk-based customer onboarding and periodic screening for AML compliance.

  • The Cellule Nationale de Traitement des Informations Financières (CENTIF-Sénégal) is Senegal’s financial intelligence unit responsible for enforcing AML/CFT compliance and receiving STRs

  • NGOs, money transfer operators, and remittance platforms must screen both senders and beneficiaries against UN and regional sanctions lists, especially for high-risk corridors or conflict zones.

  • Anqa provides tools for digital onboarding, customer risk scoring, and sanctions screening — helping smaller institutions meet regulatory expectations affordably and efficiently.