Higher Risk
 
Medium Risk
 
Info n/a
 
Lower Risk
Bilateral exchange of information
Agreements in place?
    No
Sanctions:

None applicable

____________________________________________________

Offshore Jurisdiction Blacklists – Further Information:

Information unavailable.

____________________________________________________

US State Department Money Laundering Report - 2011:

Benin is not a financial center. It is a regional re-export hub,
particularly for trafficked vehicles. A large percentage of motor
fuels sold in Benin is informally imported from Nigeria. There is
also significant informal trade in consumer goods with Nigeria,
including medicines and vegetable oil. Internet and other fraud
schemes are common. Benin is a transit point for cocaine and
heroin moving from Latin America to Europe. Human trafficking
and corruption are also concerns. There is no indication the
informal markets are funded through narcotics proceeds. While
some money laundering may occur through Benin's banking
system, Government of Benin (GOB) officials believe money
laundering is undertaken primarily through the purchase of assets
such as real estate, shipment of used vehicles for resale, and
front companies.

CRIMINALIZATION OF MONEY LAUNDERING:

“All serious crimes” approach or “list” approach to predicate
offenses: All serious crimes

Legal persons covered: criminally: YES civilly: YES

CRIMINALIZATION OF TERRORIST FINANCING:

Ability to freeze terrorist assets without delay: NO

UN lists of designated terrorists or terrorist entities distributed to
financial institutions: YES

KNOW-YOUR-CUSTOMER RULES:

Covered entities: Banks, cash couriers, casinos, insurance
companies, post office, real estate agents, lawyers, notaries, non-
governmental organizations, travel agents, and dealers of
precious metals, stones and artifacts

Enhanced due diligence procedures for PEPs: Foreign: NO
Domestic: NO

SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:

Covered entities: Banks, cash couriers, casinos, insurance
companies, post office, real estate agents, lawyers, notaries, non-
governmental organizations, travel agents, and dealers of
precious metals, stones and artifacts

Number of STRs received and time frame: Not available

Number of CTRs received and time frame: Not available

MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:

Prosecutions: Twelve over the last three years

Convictions: None

Assets forfeited: criminally: None civilly: None

RECORDS EXCHANGE MECHANISM:

With U.S.: YES

With other governments/jurisdictions: YES

Benin is a member of the Inter Governmental Action Group
Against Money Laundering in West Africa (GIABA), a Financial
Action Task Force (FATF)-style regional body. Its most recent
mutual evaluation can be found here: http://www.giaba.org/index.
php?type=c&id=38&mod=2&men=2

ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:

Although the GOB has taken specific steps to construct an anti-
money laundering/counter-terrorist financing (AML/CFT) regime,
its level of compliance and implementation measured against
international standards is low. There is a lack of overall AML/CFT
countermeasures by both industry and responsible government
agencies. AML measures suffer from lapses of information
sharing and cooperation between government agencies and
departments. Benin law enforcement is hindered by a lack of
financial crimes expertise. There is little data to reliably measure
progress in combating money laundering.

Know your customer and suspicious transaction reporting
requirements are not routinely implemented. With the exception of
cash couriers, who must declare the transfer of funds equal to or
exceeding 2,000,000 FCFA (approximately $4,000) across
borders, AML/CFT controls are not applied to non-bank financial
institutions (NBFI), despite their coverage under the law. Benin
customs authorities do not evaluate cross-border currency
declarations for money laundering purposes and do not share the
data with the financial intelligence unit. The GOB should work with
regional partners and international donors and provide AML
training and awareness to those with responsibilities under the law.

____________________________________________________

US State Dept Narcotics Report 2012:

Benin is a transit country for drugs, including cannabis, cocaine,
methamphetamine, and heroin, with related laundering of
trafficking proceeds. The volume of drugs transiting Benin is
unclear, but cocaine and heroin transit West African countries,
including Benin, en route to Europe. Cannabis is cultivated in
central Benin for local consumption and regional sale.

There are indications that large cocaine shipments originating
from South America and heroin from Southwest Asia enter Benin
via maritime vessels and cargo containers for further distribution
in West Africa and to Europe.

In April 2011, U.S. government officials assisted local law
enforcement to seize a shipping container filled with used clothes
that concealed 200 kilograms of heroin. The shipping container
originated in Pakistan and was destined for Europe. On June 7,
French law enforcement separately assisted in the seizure of 400
kilograms of cocaine originating from South America destined for
Niger; the cocaine was concealed inside large irrigation system
valves. Methamphetamine has been seized in Belgium, Japan,
Malaysia, Thailand and Vietnam from couriers and in air cargo
originating in Cotonou. In November 2011, methamphetamine
secreted in motor parts was seized at Liege Airport in Belgium.
The drugs originated in Benin, with a final destination of Malaysia.
Drug traffickers reportedly launder drug proceeds through
purchase and import of second-hand vehicles from the United
States and Europe.

The Government of Benin (GOB) Central Office for Repression of
Illicit Trafficking of Drugs and Precursors (OCERTID) is the
national lead agency for combating narcotics trafficking. OCERTID
supports and coordinates anti-drug activities of the police,
Gendarmerie, customs, forestry service and other offices.
However, the effectiveness of this coordination is limited since
many positions in OCERTID remain unfilled. OCERTID responds
to reports of illicit drug trafficking and maintains enforcement
offices in the city of Cotonou, including Benin's international
airport and the Port of Cotonou. The airport has been used as an
entry point to bring drugs into and through Benin. President Boni
Yayi visited the Cotonou airport in late 2011 to ensure that proper
security measures are put in place to combat drug trafficking.
Recent drug seizures have primarily included cannabis, cocaine,
and heroin. OCERTID's reported seizures from January to
September 2011 were: 246.5 kilograms of cannabis; 424.4
kilograms of cocaine; and 200.2 kilograms of heroin. As a matter
of policy, the Government of Benin does not encourage or
facilitate illicit production or distribution of narcotic or psychotropic
drugs or other controlled substances, or the laundering of
proceeds from illegal drug transactions.

Benin's Law on Control of Drugs and Precursors, the Criminal
Code, and the Code of Criminal Procedure criminalizes narcotics-
related money laundering, and provides penalties of up to 20
years in prison and fines up to CFA 5 million ($10,000, at current
exchange rates) for trafficking of drugs and psychotropic
substances. Benin is a party to the 1988 UN Drug Convention, the
UN Convention against Transnational Organized Crime and the
UN Convention against Corruption. The GOB has established an
Inter-ministerial Committee for Control of Drugs and Psychotropic
Substances (CILAS) and drafted a National Anti-Drug Policy
(POLUDRO) to address drug abuse and trafficking.

The UNODC is assisting the GOB to draft an Integrated National
Program to curb drug abuse and trafficking. UNODC and other
development partners, including the Millennium Challenge
Corporation, are assisting the GOB to increase security at the
Port of Cotonou, including improving shipping container
inspections. The GOB coordinated a nationwide drugs awareness
campaign as a key activity of its observance of the 2011
International Day against Drug Abuse and Illicit Trafficking. In May
and June 2011, CILAS conducted drug awareness training with
students and local government in eight departments of Benin. The
GOB continues to address drug abuse and trafficking through
education and enforcement of anti-drug legislation.

For Full report, click here

____________________________________________________

US State Dept Trafficking in Persons Report 2011
(introduction):

(Tier 2)

Benin is a country of origin and transit for children, and possibly
men and women, subjected to forced labor and sex trafficking.
The majority of victims are girls subjected to forced domestic
service or sex trafficking in Cotonou, the administrative capital.
Children are also forced to labor on farms or construction sites, to
produce handicrafts, or hawk items on the street. The majority of
child trafficking victims are from the northern regions of Benin.
Reports indicate that children may be exploited in the sex trade
near Pendjari National Park in northwest Benin to meet the
demand of foreign tourists. Children are recruited and transported
to Nigeria and Gabon, and to a lesser extent Cote d’Ivoire,
Ghana, Democratic Republic of the Congo, Togo, Cameroon, and
Niger, where they are forced to labor in mines, quarries,
restaurants, street vending, and on cocoa farms.

The Government of Benin does not fully comply with the minimum
standards for the elimination of trafficking; however, it is making
significant efforts to do so. The government acknowledges that
child trafficking is a problem in Benin, and during the year
authorities continued to proactively identify child victims and
coordinate efforts to provide for their short and long-term
protection. The government identified 241 victims during the year
and prosecuted an unknown number of trafficking offenders.
However, the government does not recognize the trafficking of
adults, and despite reports of children held in commercial sexual
exploitation, it neither investigated nor apprehended any
suspected sex traffickers during the year.

For full report click here

____________________________________________________

US State Dept Terrorism Report 2009

No report available

____________________________________________________

Links:

Worldwide AML Legislation (International Bar Association)
Tables & Rankings
Are there Sanctions in force against it? (UN/EU/US)
N
?
Is it on FATF list of non-cooperative countries?
N
?
Is it on OECD list of uncooperative Tax Havens?
N
?
OECD - Implementation status of Tax Standard
 
?
Is it on EU 'white' list of equivalent jurisdictions?
N
?
Offshore Finance Center (Original IMF List)?
N
?
Is it on the US Secretary of Treasury list of jurisdictions of
Primary Money Laundering concern?
N
?
Is it on the US Secretary of State list of jurisdictions
identified to be supporters of International Terrorism?
N
?
Is it on US Department of State International Narcotics
Control Majors List?
N
?
US Dept of State Money Laundering assessment (INCSR)
M
?
Government Actions (For further info see INCRS below):
 
?
-  Criminalized Drug Money Laundering?
Y
 
-  Criminalized Beyond Drugs?
Y
 
-  Record Large Transactions?
N
 
-  Maintain Records Over Time?
Y
 
-  Report Suspicious Transactions?(NMP)?
Y
 
-  Financial Intelligence Unit?
Y
 
-  System for Identifying/Forfeiting Assets?
Y
 
-  Arrangements for Asset Sharing?
N
 
-  Cooperates with International Law Enforcement?
Y
 
-  International Transportation of Currency?
Y
 
-  Ability to Freeze Terrorist Assets w/o delay?
Y
 
-  Disclosure Protection "Safe Harbor"?
Y
 
-  Criminalized Financing of Terrorism?
N
 
-  States Party to 1988 UN Convention?
Y
 
-  International Terrorism Financing Convention?
Y
 
 
Ranking
2011
Ranking
2010
 
Corruption (Transparency International)
100 (out of
183)
110 (out of
178)
?
Ease of doing business (World Bank)
175 (out of
183)
170 (out of
183)
?
FATF 40 + 9 recommendations
Mutual Evaluation Report: 2010
C
L
P
N
N/A
    C  -  Fully Compliant ,   
    L  -  Largely Compliant,    
    P  -  Partially Compliant    
    N  -  Non-Compliant
0
7
17
24
1
Legal Systems
 
1. Money Laundering Offence
P
 
14. Protection & no tipping-off
L
2. ML offence – mental element and
corporate liability
P
 
15. Internal controls,
compliance & audit
P
3. Confiscation and provisional
measures
L
 
16. DNFBP – R.13-15 & 21
N
4. Secrecy laws consistent with the
Recommendations
L
 
17. Sanctions
P
5. Customer due diligence
N
 
18. Shell banks
N
6. Politically exposed persons
N
 
19. Other forms of reporting
N
7. Correspondent banking
N
 
20. Other NFBP & secure
transaction techniques
N
8. New technologies & non
face-to-face business
P
 
21. Special attention for
higher risk countries
N
9. Third parties and introducers
N
 
22. Foreign branches &
subsidiaries
N
10. Record keeping
P
 
23. Regulation, supervision
and monitoring
P
11. Unusual transactions
N
 
24. DNFBP - regulation,
supervision and monitoring
N
12. Designated Non-Financial
Businesses and Professions – R.5,
6, 8-11
N
 
25. Guidelines & Feedback
P
13. Suspicious transaction reporting
P
     
Institutional and other
measures
 
26. The FIU
P
 
31. National co-operation
P
27. Law enforcement authorities
P
 
32. Statistics
P
28. Powers of competent authorities
L
 
33. Legal persons – beneficial
owners
N
29. Supervisors
N
 
34. Legal arrangements –
beneficial owners
N/A
30. Resources, integrity and training
P
 
 
 
International Co-operation
 
35. Conventions
P
 
38. MLA on confiscation and
freezing
P
36. Mutual legal assistance (MLA)
L
 
39. Extradition
L
37. Dual criminality
L
 
40. Other forms of
co-operation
P
Nine Special
Recommendations
 
SR.I Implement UN instruments
N
 
SR VI AML requirements for
money/value transfer services
N
SR.II Criminalise terrorist financing
N
 
SR VII Wire transfer rules
N
SR.III Freeze and confiscate terrorist
assets
N
 
SR.VIII Non profit
organisations
N
SR.IV Suspicious transaction
reporting
N
 
SR.IX Cross Border
Declaration & Disclosure
N
SR.V International co-operation
N
 
 
 
*Please note that FATF deems that a country has significant aml deficiencies if any
of the 'Core' Recommendations, R1, R5, R10, R13, SRII, or SRIV are rated either
Partially of Non-Compliant. These are marked in red.

For FATF to remove a country from the regular follow-up process, it has to be rated
Compliant or Largely Compliant in the above mentioned Core Recommendations
and the following Key Recommendations: -        

R3, R4, R23, R26, R35, R36, R40, SRI, SRIII, SRV

Please also note that any risk assessment should take into consideration all
follow-up reports.
Further Tables
BENIN
KnowYourCountry
-  Know Your Customer Provisions
N
 
-  Criminalized Tipping Off?
Y
 
-  Report Suspected Terrorist Financing?
Y
 
-  State Party to United Nations TOC?
Y
 
-  State Party to United Nations CAC?
Y
 
Local AML News / Sanctions
Tax Information
Business Information
Last Updated:   16 April 2012