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:

A regional financial center with a largely cash-based economy,
Senegal is vulnerable to money laundering. Reportedly, most
money laundering involves domestically generated proceeds from
corruption and embezzlement. Also of concern are organized
crime figures that launder and invest their personal and their
organizations’ proceeds from the growing West Africa narcotics
trade. There is also evidence of increasing criminal activity by
foreigners, such as narcotics trafficking by Latin American groups
and trafficking in persons involving Pakistanis.

Dakar’s active real estate market is largely financed by cash.
Property ownership and transfer are not transparent. The
continued building boom and high property prices suggest there
is an increasing amount of funds with uncertain origin circulating
in Senegal. The growing presence of hawala and other informal
cash transfer networks and the increasing numbers of used
imported vehicles suggest the existence of both value transfer via
trade goods and illicit cash couriers. Trade-based money
laundering (TBML) is centered in the region of Touba, a largely
autonomous and unregulated free trade zone under the
jurisdiction of the Mouride religious authority. Touba reportedly
receives between $550 and $800 million per year in funds
repatriated by networks of Senegalese traders and vendors
abroad. Other areas of concern include the transportation of
cash, gold and gems through Senegal’s airport and across its
porous borders.

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.: NO

CRIMINALIZATION OF MONEY LAUNDERING:

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

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; money exchanges; postal services;
lawyers; securities and insurance brokers; auditors; real estate
agents; dealers of high value goods such as art objects, precious
stones, and metals; transporters of funds; casinos and gambling
establishments, including state lotteries; travel agencies; non-
governmental organizations, the Public Treasury

Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: YES

SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:

Covered entities: Banks; money exchanges; postal services;
lawyers; securities and insurance brokers; auditors; real estate
agents; dealers of high value goods such as art objects, precious
stones, and metals; transporters of funds; casinos and gambling
establishments, including state lotteries; travel agencies; non-
governmental organizations

Number of STRs received and time frame: 71 in 2009

Number of CTRs received and time frame: Not applicable

MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:

Prosecutions: Nine in 2009

Convictions: Not available

Assets forfeited: criminally: Not available civilly: Not available

RECORDS EXCHANGE MECHANISM:

With U.S.: YES

With other governments/jurisdictions: YES

Senegal is a member of the Intergovernmental Action Group
against Money Laundering in West Africa (GIABA), a Financial
Action Task Force-style regional body. Its most recent mutual
evaluation is available here: http://www.giaba.org/index.php?
type=c&id=37&mod=2&men=2

ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:

The Government of Senegal (GOS) should continue to work with
its partners in GIABA, the West African Economic and Monetary
Union (WAEMU) and the Economic Community of West African
States (ECOWAS) to develop comprehensive anti-money
laundering/counter-terrorist financing (AML/CFT) regime. Senegal
should continue to battle corruption and increase the frequency,
transparency, and effectiveness of financial reviews and audits of
financial institutions. Senegal should establish better uniform
control of the cross-border flow of currency and other bearer-
negotiable instruments for both residents and nonresidents.
Senegalese law enforcement and customs authorities need to
develop their expertise in identifying and investigating both
traditional money laundering and money laundering within the
informal economy as well as value transfer via trade goods. The
Senegalese financial intelligence unit – CENTIF - should perform
more outreach to obligated non-bank financial institutions to
ensure a better understanding of the content and filing
requirements for STRs. CENTIF, law enforcement, and Ministry of
Justice authorities should work together to coordinate roles and
responsibilities with regard to case investigation and assembly,
and develop a deeper interagency understanding of money
laundering and terrorist financing.

____________________________________________________

US State Dept Narcotics Report 2012:

Senegal serves as a transit country for drug traffickers due to its
location, infrastructure and porous borders. The country's
location on the west coast of Africa, along with a well-serviced
international airport and an active seaport, make it an enticing
transit point for drug traffickers. Narcotics are trafficked through
Senegal by vehicle and boat from countries to the south of
Senegal, including Guinea-Bissau and Guinea. The U.S. is not a
destination point for these drugs.

Cannabis, a traditionally popular drug in Senegal, is cultivated in
the southern Casamance region. According to the UN Office on
Drugs and Crime (UNODC), Senegal may become the leading
producer of cannabis among the Francophone countries of West
Africa and the third largest producer in West Africa after Nigeria
and Ghana. Cocaine abuse in Senegal is also on the rise.
UNODC estimates that about 40 tons of cocaine from Latin
America reaches Europe via West Africa each year. However,
Senegal and its neighbors are unprepared to deal with increasing
levels of drug trafficking. Law enforcement officials lack the means
and infrastructure to track smugglers, and poorly equipped local
authorities face an uneven battle against the cash-wealthy
traffickers.

Senegal’s Drug Law of 1997 is the country’s basic law on drugs; it
covers the entire breadth of policy from apprehending and
punishing offenders to rehabilitating abusers and was amended in
2006 to include stiffened penalties for drug traffickers. In 2011, at
least 65 Senegalese and foreign individuals were prosecuted and
convicted for drug trafficking. Senegal has a national plan of
action, originally created in 1998, to combat drug abuse and the
trafficking of drugs. Multidisciplinary in its approach, Senegal's
national plan includes objectives to control the cultivation,
production and traffic of drugs; to inform the population of the
dangers of drug use; and to reintroduce former drug addicts into
society. However, the government lacks the financial means to
effectively counter the threats, and therefore frequently falls short
of achieving plan objectives.

Senegal works with its partners in the Economic Community of
West African States (ECOWAS) to combat cocaine trafficking.
Senegal also has several bilateral agreements with neighboring
countries to combat narcotics trafficking and has signed mutual
legal assistance agreements with the United Kingdom and France
to facilitate exchange of enforcement information on narcotics
trafficking and other transnational crimes. In April 2011, the U.S.
and Senegal signed a maritime bilateral agreement that, among
other objectives, will strengthen Senegal’s maritime capacity to
counter drug trafficking. Senegal is a party to the 1988 UN Drug
Convention, the UN Convention against Corruption, and the UN
Convention against Transnational Crime and its three protocols.

The Senegalese government does not, as a matter of government
policy, 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. No
senior government officials are known to engage in, encourage or
facilitate the illicit production or distribution of such drugs or
substances, or the laundering of proceeds from illegal drug
transactions. Though corruption is a problem for narcotics law
enforcement all over Africa, narcotics-related corruption does not
appear to be a problem within senior levels of the Senegalese
government.

In July, 2011, the U.S. Coast Guard conducted a 15 day African
Maritime Law Enforcement Partnership mission involving joint
training, surveillance, and law enforcement operations in support
to suppress illicit transnational maritime activity in and around
Senegal waters.

The Senegalese government has demonstrated political will to
fight drug trafficking, though its efforts are hampered due to lack
of infrastructure and funding. Its national plan to counter narcotics
trafficking and its cooperation with regional neighbors are both
positive and necessary steps to help Senegal in this fight.
However, Senegal, like its neighbors, continues its struggle to
track and prevent traffickers who have greater resources.
Senegal’s geographical location creates a tempting point for drug
traffickers seeking to move narcotics from South America to
Europe, and its proximity to Guinea-Bissau, a country plagued by
a severe narco-trafficking problem, presents an ongoing
challenge as Senegal tries to maintain its borders and also handle
illicit marijuana cultivation in the Casamance region.

____________________________________________________

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

(Tier 2)

Senegal is a source, transit, and destination country for children
and women subjected to forced labor, forced begging, and sex
trafficking. NGOs estimate that at least 50,000 children in the
country, most of whom are talibes – students attending daaras
(Koranic schools) run by teachers known as marabouts − are
forced to beg, and that in Dakar alone there are 8,000 of these
children begging in the streets. In addition to forced begging,
Senegalese boys and girls are subjected to domestic servitude,
forced labor in gold mines, and commercial sexual exploitation.
Trafficking within the country is more prevalent than transnational
trafficking, though children from neighboring countries have been
found in forced begging and other forms of forced labor in
Senegal. Unscrupulous marabouts in Senegal force boys from
The Gambia, Mali, Guinea-Bissau, and Guinea to beg and boys
from Guinea also are forced to work in gold mines. Senegalese
women and girls are transported to neighboring countries,
Europe, and the Middle East for domestic servitude. NGO
observers believe most women and girls in forced prostitution,
however, remain in Senegal. Women and girls from other West
African countries, particularly Liberia, Ghana, Guinea, Guinea-
Bissau, Sierra Leone, and Nigeria, may be subjected to domestic
servitude and commercial sexual exploitation in Senegal, including
for international sex tourism.

The Government of Senegal does not fully comply with the
minimum standards for the elimination of human trafficking;
however, it is making significant efforts to do so. The government
renewed its efforts to prosecute and convict abusive marabouts
for forcing talibe boys to beg; sustained its commitment to provide
shelter, rehabilitation, and reintegration services to talibe boys;
and increased efforts to raise awareness about the dangers of
the culturally entrenched practice of child begging connected with
religious education. The government did not take steps, however,
to raise awareness of the dangers of other forms of trafficking,
nor did it proactively identify and provide assistance to victims in
other trafficking situations, such as boys forced to work in mines
or women and girls forced into commercial sexual exploitation.

For full report click here

____________________________________________________

US State Dept Terrorism Report 2010

Legislation and Law Enforcement: Senegal does not have a
terrorism-specific law but offenses are captured under other parts
of the penal code. For example, Senegalese legislation
criminalizes illegal possession of a firearm. Possession, bearing,
transporting, importation, and marketing of weapons and
ammunitions are subject to prior authorization from the Ministry of
Interior.

Countering Terrorist Finance: Senegal has an anti-money
laundering/countering terrorist finance legal framework in place
via the West African Economic and Monetary Union Uniform Law.
Senegal’s Financial Intelligence Unit is called CENTIF, and is a
member of the Egmont Group. CENTIF, law enforcement, and
Ministry of Justice authorities worked to coordinate roles and
responsibilities and to develop a deeper interagency
understanding of terrorist financing. The Central Bank of West
African States and CENTIF circulated the UN 1267 Sanctions
Committee consolidated list to commercial financial institutions.
Senegal 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: Senegal cooperated with
U.S. counterterrorism efforts and is a Trans-Sahara
Counterterrorism Partnership country. Senegal signed the Beijing
Convention on the Suppression of Unlawful Acts Relating to
International Civil Aviation and the Protocol to the Convention for
the Suppression of Unlawful Seizure of Aircraft at the conclusion
of an International Civil Aviation Organization diplomatic
conference in September.

____________________________________________________

Links:

Cellule Nationale de Traitement des Informations Financières
National Financial Intelligence Processing Unit (CENTIFSENEGAL)

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)
C
?
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?
Y
 
-  Ability to Freeze Terrorist Assets w/o Delay?
Y
 
-  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)
112 (out of
183)
105 (out of
178)
?
Ease of doing business (World Bank)
154 (out of
183)
152 (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
6
13
16
12
2
Legal Systems
 
1. Money Laundering Offence
L
 
14. Protection & no tipping-off
C
2. ML offence – mental element and
corporate liability
L
 
15. Internal controls,
compliance & audit
P
3. Confiscation and provisional
measures
L
 
16. DNFBP – R.13-15 & 21
P
4. Secrecy laws consistent with the
Recommendations
C
 
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
L
8. New technologies & non
face-to-face business
P
 
21. Special attention for
higher risk countries
N
9. Third parties and introducers
N/A
 
22. Foreign branches &
subsidiaries
N
10. Record keeping
L
 
23. Regulation, supervision
and monitoring
P
11. Unusual transactions
L
 
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
L
 
31. National co-operation
L
27. Law enforcement authorities
L
 
32. Statistics
P
28. Powers of competent authorities
C
 
33. Legal persons –
beneficial owners
P
29. Supervisors
L
 
34. Legal arrangements –
beneficial owners
N/A
30. Resources, integrity and training
L
 
 
 
International Co-operation
 
35. Conventions
P
 
38. MLA on confiscation and
freezing
C
36. Mutual legal assistance (MLA)
C
 
39. Extradition
L
37. Dual criminality
C
 
40. Other forms of
co-operation
L
Nine Special
Recommendations
 
SR.I Implement UN instruments
P
 
SR VI AML requirements for
money/value transfer services
P
SR.II Criminalise terrorist financing
P
 
SR VII Wire transfer rules
N
SR.III Freeze and confiscate
terrorist assets
P
 
SR.VIII Non profit
organisations
N
SR.IV Suspicious transaction
reporting
N
 
SR.IX Cross Border
Declaration & Disclosure
P
SR.V International co-operation
P
 
 
 
*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.
SENEGAL
KnowYourCountry
-  Know Your Customer Provisions
Y
 
-  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
Extracted from IMF Report  -  Senegal: Second Review Under
the Policy Support Instrument and Request for Modification of
Assessment Criteria (December 2011)

The government reiterates its commitment to improve the transparency
of the economic and financial operations of the state and to promote
good governance in the administration:

1. The proposals for amending the law on the Court of Audit in order to
improve its functionality and effectiveness in auditing the government’s
accounts were approved by the Council of Ministers and the draft law
containing the amendments will be submitted to Parliament in December
2011.

2. CENTIF has published on its website the end-June statistics on cases
of money laundering and the financing of terrorism, showing the number
of suspicious cases received, the number of cases submitted to the
Public Prosecutor’s Office, the number of judicial prosecutions, and the
number of convictions. This reporting will be continued on a semiannual
basis.

3. The process of improving transparency in land transactions and
publishing sales of government property to private parties is moving
forward gradually. The first stages of computerizing real estate
management, namely the scanning and restoration of land
registries begun in 2008, is expected to be completed in 2013. For 2012,
the main objective is to ensure the availability, accessibility, and
reliability of the land data using more transparent procedures. The
introduction of a new property information system will be based on:

(a) consolidation of the modernization of the cadaster;

(b) the creation of a computerized land registry; and (c) the
computerization of government domain management including, on a
priority basis, the inventory of government properties for preparation of
the Summary Table of Government Properties. Beginning in 2012, the
Minister of Economy and Finance will publish at the end of each year, on
a publicly available website, all the information on the number of cases
involving final sales of land from the government’s private domain,
indicating the surface area of the land sold, its geographic location, and
the corresponding revenue received. Beginning in January 2012, all
government land receipts will be tracked in SIGTAS in the same manner
as all other tax receipts collected by the DGID.

Anti Money Laundering / Combating the Financing of Terrorism

The onsite visit for Senegal's AML/CFT evaluation took place in
July/August 2007 in the context of ECOWAS’s Inter-Governmental Action
Group Against Money Laundering in West Africa (GIABA). The report
was adopted in early May 2008 by the GIABA Plenary held in Accra,
Ghana. The report highlighted several areas of weaknesses in the
AML/CFT system, confirmed by a score of 12 Non-Compliant and 16
Partially Compliant ratings out of the 40+9 FATF AML/CFT
Recommendations. GIABA’s First Follow Up Report of 2009 on
the implementation of the recommendations contained in the Mutual
Evaluation Report mentions that Senegal’s adoption of Uniform Law No.
2009-16 of March 2, 2009 against terrorist financing enables the country
to broadly comply with all the Recommendations and Special
Recommendations concerning the issue, including customer due
diligence (especially as regards politically exposed persons - PEPs). It
also notes that legal provisions taken by Senegal in order to prevent the
abuse of new technologies, namely the adoption of Law No.
2008–11 of January 25, 2008 on cyber criminality, enable the country to
adapt its criminal system and subsequent procedures to crimes related
to new information and communication technologies. Senegal joined the
Egmont Group of Financial Intelligence Units in May 2009.

Since end-June 2011, the FIU (CENTIF) publishes on its website
statistics on suspicious transaction reports cases received, the number
of cases transmitted to the judiciary as well as the number of convictions.
The GIABA Secretariat concludes that Senegal deserves
encouragement for its endeavor to reinforce its AML/CFT scheme and
recommends, at this juncture, to maintain Senegal within the regular
follow-up process, pending the results of measures taken and the
adoption of new measures aimed at amending the above-mentioned
scheme. The discussion of Senegal’s Third Follow-Up Report was
postponed until May 2012 to give the authorities the opportunity to
provide more detailed information on the progress made in addressing
the remaining deficiencies.

Click here to view full report
Last Updated:   16 April 2012