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

None applicable

____________________________________________________

Offshore Jurisdiction Blacklists:

Information unavailable.

____________________________________________________

US State Department Money Laundering Report - 2011:

Mali is a member of the West African Economic and Monetary
Union (WAEMU), which also includes Benin, Burkina Faso, Cote D’
Ivoire, Guinea-Bissau, Niger, Senegal, and Togo. All of the
WAEMU members share a common currency, the franc CFA. The
currency is pegged to the euro and guaranteed by France.

Mali is not a regional financial center, and presently, there are no
free trade zones or offshore sectors in Mali. The danger of
laundering of illegal proceeds arises from well-travelled trafficking
routes moving drugs, small arms, people, and everyday
commodities across the Algerian and Mauritanian borders in the
sparsely-populated north of the country. Terrorist cells from Al-
Qaeda in the Islamic Maghreb (AQIM), known to operate in the
north, are suspected of involvement in these smuggling routes.
On the 2010 Corruption Index sponsored by Transparency
International, Mali placed 116th out of 178 (with 178 being the
most corrupt), dropping from 111th in 2009.

DO FINANCIAL INSTITUTIONS ENGAGE IN CURRENCY
TRANSACTIONS RELATED TO INTERNATIONAL NARCOTICS
TRAFFICKING THAT INCLUDE SIGNIFICANT AMOUNTS OF US
CURRENCY; CURRENCY DERIVED FROM ILLEGAL SALES IN
THE U.S.; OR THAT OTHERWISE SIGNIFICANTLY AFFECT THE
U.S.: UNKNOWN

CRIMINALIZATION OF MONEY LAUNDERING:

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

Legal persons covered: criminally: YES civilly: YES

CRIMINALIZATION OF TERRORIST FINANCING:

Ability to freeze terrorist assets without delay: YES

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

(Please refer to the Department of State’s Country Reports on
Terrorism, which can be found here: http://www.state.
gov/s/ct/rls/crt/)

KNOW-YOUR-CUSTOMER RULES:

Covered entities: Banks, the Public Treasury, microfinance
entities, the post office, currency exchanges, insurance
companies and brokers, securities and asset brokers and
managers, the regional stock exchange, mutual funds, casinos

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

SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:

Covered entities: Financial organizations, Banks, the Public
Treasury, microfinance entities, the post office, currency
exchanges, insurance companies and brokers, securities and
asset brokers and managers, the regional stock exchange, mutual
funds, attorneys, notaries, auditors, real estate and travel agents,
non-governmental organizations, casinos and gaming
establishments, and dealers of high-value goods and precious
metals and stones

Number of STRs received and time frame: 25 in 2010

Number of CTRs received and time frame: None in 2010

MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:

Prosecutions: Five in 2010

Convictions: None in 2010

Assets forfeited: criminally: None in 2010 civilly: None in 2010

RECORDS EXCHANGE MECHANISM:

With U.S.: YES

With other governments/jurisdictions: YES

Mali 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 report can be found here: http://www.giaba.
org/media/M_evalu/MALI_word_MER_english[1].pdf

ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:

Mali’s financial intelligence unit, the Cellule Nationale de
Traitement des Informations Financières (CENTIF) is confident
that closer relations with foreign financial intelligence units will
improve the number of prosecutions for financial crimes, and will
also elucidate the sources and possible destinations of laundered
funds. CENTIF enjoys a transparent and mutually beneficial
relationship with liaison officers from the customs service, police,
and gendarme forces. Significant challenges to CENTIF’s
efficiency remain lack of funds to mount comprehensive
awareness training for bank and public sector employees as well
as adequate publicity for the organization itself.

Although many types of entities are listed as covered under Mali’s
anti-money laundering law, very few are actually conforming to
requirements and, with the exception of casinos, designated non-
financial businesses and professions are not subject to customer
due diligence requirements.

CENTIF suspects that proceeds from cocaine trafficking into
Europe from South America may be passed through Malian
banks, but CENTIF lacks the necessary cooperation with external
banks to make this determination.

____________________________________________________

US State Dept Narcotics Report 2012:

The extremely limited resources of the government and the sheer
size of Mali's three northern regions – whose sparsely populated
desert is larger than the state of Texas – makes it a challenge to
interdict drug smugglers. Historically, illicit drugs in Mali were
limited to cannabis in both herb and resin form, most of which was
consumed locally. In recent years, however, foreign smugglers
have begun to engage in trafficking of cocaine from South
America through Mali to Western Europe. In 2009, a Boeing 727
aircraft crash-landed in northern Mali, where an undisclosed but
by all accounts significant quantity of cocaine is purported to have
been offloaded before the plane was abandoned. Half a dozen
arrests followed over a year after the incident occurred; as yet,
there have been no convictions. Mali has been authoritatively
identified as one of the West African transit countries through
which up to 80 percent of cocaine seized in Western Europe can
be traced. It is only recently that information has been developed
which indicates unpopulated areas in the North of Mali may be
being used for the reception of clandestine air shipments of
cocaine as well as for the land transportation of quantities of
cocaine and hashish across northern Mali. Some of the subjects
facilitating this activity are believed to be associated with ethnic
militias and/or extremist elements such as AQIM(al-Qaeda in the
Islamic Maghreb).

Mali is a party to the 1988 UN Drug Convention, the UN
Convention against Transnational Organized Crime and the UN
Convention against Corruption. There is no extradition treaty or
mutual legal assistance treaty in force between the United States
and Mali. Legal assistance, however, has been sought and
afforded through letters of request.

The Malian National Police Counterdrug Brigade is the primary
law enforcement body for combating drugs. Malian police seized
over 900 kg of illegal substances during 2011 to date, of which
three kilos were cocaine, five kilos were amphetamine-type
stimulants, 837 kilos were cannabis herb or resin, and 97 kilos
were other controlled substances, mainly prescription drugs.

Mali's chief policy organization for addressing drug issues is the
Inter-ministerial Drug Committee, chaired by the Ministry of
Justice. The committee includes members from eight ministries,
with the commander of the Counterdrug Brigade serving as
secretary. This committee is the focal point for implementation of
Mali's five-year National Integrated Program (NIP) on Narcotics,
adopted in 2009, whose goals include increasing law enforcement
capacity, deterring transnational criminal operations, and
controlling and minimizing the spread of drug consumption. The
NIP resulted from the ECOWAS Regional Action Plan as well as
the ECOWAS Political Declaration on the Prevention of Drug
Abuse, Illicit Drug Trafficking, and Organized Crime in West Africa
(both signed in 2008). Shortages of basic communications and
police vehicle support suggest that new initiatives or programs to
expand counterdrug operations in Mali during the coming year are
unlikely.

Mali is not considered to have a serious drug consumption or
dependence problem. Most hard drugs which transit the country
are destined for markets in Europe, and local society is culturally
resistant to drug abuse. Few official statistics on drug abuse exist.
One of the NIPs goals is a comprehensive assessment of the drug
abuse situation in Mali.

As a matter of government policy, Mali 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.

Mali will continue to serve as a transit country for drugs headed to
Western Europe. Its involvement in the drug trade is buoyed by
high cocaine prices in foreign markets, the difficulty of patrolling
northern Mali, and Mali’s fundamental lack of law enforcement
resources.

For Full report, click here

____________________________________________________

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

(Tier 2 Watch List)

Mali is a source, transit, and destination country for men, women,
and children subjected to forced labor and sex trafficking. Within
Mali, women and girls are forced into domestic servitude,
agricultural labor, and support roles in gold mines, as well as
subjected to sex trafficking. Malian boys are found in conditions of
forced labor in agricultural settings, gold mines, and the informal
commercial sector, as well as forced begging both within Mali and
neighboring countries. Reports indicate that Malian children are
transported to Senegal and Guinea for forced labor in gold mines
and on cotton and cocoa farms in Cote d’Ivoire. Boys from Mali,
Guinea, Burkina Faso, Niger, and other countries are forced into
begging and exploited for labor by religious instructors within Mali
and across borders. Women and girls from other West African
countries are subjected to prostitution in Mali. In December 2010,
an INTERPOL operation rescued three Malian children being held
in situations of forced labor in Gabon. Malians and other Africans
who travel through Mali to Mauritania, Algeria, or Libya, in hopes
of reaching Europe, are particularly at risk of becoming victims of
human trafficking. Adult men and boys, primarily of Songhai
ethnicity, are subjected to the longstanding practice of debt
bondage in the salt mines of Taoudenni in northern Mali. Some
members of Mali’s black Tamachek community are subjected to
traditional slavery-related practices rooted in hereditary master-
slave relationships, and this involuntary servitude reportedly has
extended to their children.

The Government of Mali does not fully comply with the minimum
standards for the elimination of trafficking; however, it is making
significant efforts to do so. The government acknowledged that
human trafficking is a problem in Mali, but it did not demonstrate
significant efforts to prosecute and convict trafficking offenders.
Although the government identified at least 198 trafficking victims
during the year – 152 of whom were Malian children in prostitution
– it prosecuted only three trafficking cases and convicted two
trafficking offenders. Despite its ministerial approval in June 2010,
a bill outlawing all forms of trafficking, including slavery, did not
reach a vote in the National Assembly. Efforts to collect data on
human trafficking prosecutions improved during the year, and in
February 2011, the government took steps to streamline its anti-
trafficking efforts when the prime minister signed a decree
creating the National Coordinating Committee for the Fight Against
Trafficking and Related Activities. The government prosecuted
three trafficking offenses during the reporting period. The
government has not prosecuted a case of traditional slavery since
1969, and it has not taken action on at least three pending cases
of traditional slavery, which have been stalled in courts for more
than two years. Therefore, Mali is placed on Tier 2 Watch List for
a third consecutive year. Mali was not placed on Tier 3 per
Section 107 of the 2008 Trafficking Victims Protection
Reauthorization Act, however, as the government has a written
plan that, if implemented, would constitute making significant
efforts to bring itself into compliance with the minimum standards
for the elimination of trafficking and is devoting sufficient
resources to implement that plan.

For full report click here

____________________________________________________

US State Dept Terrorism Report 2010

Overview: The Government of Mali called for greater regional
cooperation to counter al-Qa'ida in the Islamic Maghreb (AQIM)
and participated in training programs to increase the capacity of
its security and military forces. Although Malian leaders were
generally sincere in their desire to counter terrorism, their ability
to do so continued to be hindered by limited resources and the
lack of an adequate state presence in the distant and vast
northern regions of the country. During the year, AQIM continued
to operate in parts of northern Mali, and held, released, and
claimed to have killed hostages kidnapped for ransom. In addition,
AQIM engaged in skirmishes with the Mauritanian military on
Malian territory.

2010 Terrorist Incidents: In contrast to 2009, there were no
terrorist incidents directed against Malian interests and no
kidnappings of foreigners on Malian soil in 2010. AQIM continued
to hold hostages on Malian territory throughout the year, including
hostages kidnapped in Niger in 2010. On July 25, AQIM claimed
to have executed French citizen Michael Germaneau, whom it was
holding hostage in Mali in retaliation for French support of a
Mauritanian July 22 raid on AQIM camps in Mali. There were
conflicting reports, however, that Germaneau may have already
died, due to natural causes exacerbated by his captivity, prior to
the Mauritanian raid.

Six hostages abducted by AQIM or bandits associated with AQIM
and held in Mali were released:

* On February 23, AQIM released French citizen Pierre Camatte
who was taken hostage in Menaka, Mali in November 2009. The
release occurred after Malian courts tried the four AQIM
operatives taken into custody in April 2009 for misdemeanor arms
possession and released them for time served.
* Three Spanish aid workers kidnapped in Mauritania in
November 2009 were released in 2010, one on March 10 and the
other two on August 22.
* On April 16, AQIM released two Italian citizens, Sergio Cicala
and his wife Philomene Kaboure, who had been held hostage in
Mali since their kidnapping in December 2009 in Mauritania.

Legislation and Law Enforcement: The Malian judiciary did not
prosecute any terrorist cases except in connection with the
release of Pierre Camatte.

Countering Terrorist Finance: In November, the Malian National
Assembly adopted legislation to strengthen the authority of the
National Financial Information Processing Unit, Mali’s Financial
Intelligence Unit. The National Assembly also reinforced the
judicial controls available to Malian authorities to counter terrorist
financing and money laundering offenses, as well as bring Malian
code into conformity with regional standards and the International
Convention on the Suppression of the Financing of Terrorism.
The legislation had not been signed by the President of Mali at
year’s end, however. Mali is a member of the Inter Governmental
Action Group against Money Laundering in West Africa, a
Financial Action Task Force-style regional body.

Regional and International Cooperation: Mali ratified the
Amendment to the Convention on the Physical Protection of
Nuclear Material. Mali continued to press for greater regional
cooperation to counter terrorism. Mali cooperated with U.S.
counterterrorism efforts and is a Trans-Sahara Counterterrorism
Partnership country. Along with Mauritania, Niger, and Algeria,
Mali participated in the establishment of a Joint Command Center
in Tamanrasset, Algeria, that once fully operational will allow the
four countries to coordinate regional responses to AQIM activities.

____________________________________________________

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/Terrorist Safe Haven?
S.H.
?
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
 
-  Egmont Financial Intelligence Units?
Y
 
-  System for Identifying/Forfeiting Assets?
Y
 
-  Arrangements for Asset Sharing?
Y
 
-  Cooperates with International Law Enforcement?
Y
 
-  International Transportation of Currency?
N
 
-  Ability to Freeze Terrorist Assets w/o delay?
N
 
-  Disclosure Protection "Safe Harbor"?
Y
 
-  Criminalized Financing of Terrorism?
Y
 
-  States Party to 1988 UN Convention?
Y
 
-  International Terrorism Financing Convention?
Y
 
 
Ranking
2011
Ranking
2010
 
Corruption (Transparency International)
118 (out of
183)
116 (out
of 178)
?
Ease of doing business (World Bank)
146 (out of
183)
153 (out
of 183)
?
FATF 40 + 9 recommendations
Mutual Evaluation Report: 2009
Further Tables
C
L
P
N
N/A
    C  -  Fully Compliant ,   
    L  -  Largely Compliant,    
    P  -  Partially Compliant    
    N  -  Non-Compliant
0
2
11
35
1
Legal Systems
 
1. Money Laundering Offence
P
 
14. Protection & no tipping-off
N
2. ML offence – mental element and
corporate liability
L
 
15. Internal controls,
compliance & audit
P
3. Confiscation and provisional
measures
N
 
16. DNFBP – R.13-15 & 21
N
4. Secrecy laws consistent with the
Recommendations
L
 
17. Sanctions
N
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
N
 
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
N
11. Unusual transactions
P
 
24. DNFBP - regulation,
supervision and monitoring
N
12. Designated Non-Financial
Businesses and Professions – R.5,
6, 8-11
N
 
25. Guidelines & Feedback
N
13. Suspicious transaction reporting
N
     
Institutional and other
measures
 
26. The FIU
N
 
31. National co-operation
N
27. Law enforcement authorities
P
 
32. Statistics
N
28. Powers of competent authorities
P
 
33. Legal persons – beneficial
owners
N
29. Supervisors
N
 
34. Legal arrangements –
beneficial owners
N/A
30. Resources, integrity and training
N
 
 
 
International Co-operation
 
35. Conventions
P
 
38. MLA on confiscation and
freezing
P
36. Mutual legal assistance (MLA)
N
 
39. Extradition
P
37. Dual criminality
P
 
40. Other forms of
co-operation
N
Nine Special
Recommendations
 
SR.I Implement UN instruments
P
 
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.
MALI
KnowYourCountry
-  Know Your Customer Provisions
Y
 
-  Criminalized Tipping Off?
N
 
-  KYC Provisions?
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