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:

Togo’s poor financial infrastructure and small size make its
financial institutions unlikely venues for money laundering. Its
porous borders, however, combined with its susceptibility to
corruption, make it a transshipment point in the region and sub-
region for the narcotics trade. Most narcotics passing through
Togo are believed destined for European markets.

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: Not available

Legal persons covered: criminally: YES civilly: NO

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

KNOW-YOUR-CUSTOMER RULES:

Covered entities: Banks and financial institutions

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

SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:

Covered entities: Banks and financial institutions

Number of STRs received and time frame: Three in 2010

Number of CTRs received and time frame: Three in 2010

MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:

Prosecutions: Six in 2010

Convictions: None

Assets forfeited: criminally: Not available civilly: Not available

RECORDS EXCHANGE MECHANISM:

With U.S.: YES

With other governments/jurisdictions: YES

Togo is a member of the Intergovernmental Action Group against
Money Laundering in West Africa (GIABA), a Financial Action
Task Force-style regional body. A mutual evaluation of Togo was
scheduled for 2010, and once adopted, will be found here: http:
//www.giaba.org/#

ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:

Togo’s anti-money laundering laws, including the 2009 law
covering terrorism-related financing, are enforced by a national
agency called the Cellule Nationale de Traitement des
Informations Financieres (CENTIF). It investigates suspicious bank
transfers as well as attempts to transport money across borders in
excess of the amounts allowed by law.

Both Togo’s laws and the enforcement efforts of the CENTIF are
relatively new and still gaining traction, as evidenced by the six
prosecutions this year as opposed to none last year. However,
the Government of Togo should ensure continued funding and
support for the CENTIF, as well as greater efforts to combat
corruption.

____________________________________________________

US State Dept Narcotics Report 2012:

Togo is not a significant producer of drugs; however it plays an
increasingly large role in the regional traffic in narcotics. The drug
trade (particularly in hard drugs) continued to increase, and Togo
is used more and more as a transit point for the inter-continental
movement of drugs. Togo’s capacity to address the transnational
flow of drugs is undercut, by its extreme poverty; a lack of
resources and training; long, porous borders; and an inability to
control corruption. Those challenges notwithstanding, Togo’s
counternarcotics efforts are increasing and resulted in record
seizures of illicit drugs during 2011. The only drug cultivated in
any significant quantity in Togo is cannabis, but even cannabis
cultivation is limited. Cultivation is primarily for local demand,
although some cross border distribution by small- scale dealers is
suspected. Domestic use of cannabis is increasing. Heroin and
cocaine, while not produced in Togo, are also available. Drug
abuse by Togo’s citizens is relatively rare, and there are few
crimes resulting from drug use.

There are three agencies responsible for drug law enforcement—
the police, the gendarmerie, and customs. The Central Office
Against Drugs and Money Laundering (OCRTIDB), a nominal
coordinating mechanism for these three enforcement agencies, is
responsible for investigating and arresting all persons involved in
drug-related crimes. The Director of the Central Office, in turn,
reports to the Minister of Security. The reality, however, is that the
police and gendarmerie conduct their own investigations and
enforcement operations, lending to poor accountability for seized
contraband and money. Togo is a party to the 1988 UN Drug
Convention. Togo is a party to the UN Corruption Convention and
is also a party to the UN Convention against Transnational
Organized Crime.

The number of drug-related arrests increased dramatically this
year. In just a four-month period, there were 20 seizures of some
45MT of drugs, overwhelmingly marijuana, but with significant
amounts of cocaine. The amount of cocaine seized, in particular,
increased significantly over amounts ever seized in the past in
Togo.

The National Anti-Drug Committee sponsored anti-drug films and
counter- narcotics discussion groups to advance drug abuse
education. For National Anti-Drug day, June 26, the committee
worked with civic organizations to hold a week of anti-drug
activities. As a matter of government policy, Togo does not
encourage or facilitate illegal activity associated with drug
trafficking. There is no evidence linking senior government
officials to such activity.

Although Togo’s ability to confront the issue of illicit drugs is
hampered by severe corruption problems, U.S. relations with
Togolese officials in both the Ministry of Security and the
OCRTIDB are excellent. U.S. cooperation with Togolese
counternarcotics officials will continue through the Regional
Security Officer and the regional Drug Enforcement Adminsitration
representatives based in Accra.

____________________________________________________

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

(Tier 2)

Togo is a source and transit country for men, women, and
children subjected to forced labor and sex trafficking. The majority
of Togolese victims are exploited within the country; children from
rural areas are brought to the capital, Lome, and forced to work
as domestic servants, roadside vendors, and porters, or are
exploited in prostitution. Togolese girls and, to a lesser extent,
boys are transported to Benin, Gabon, Nigeria, Ghana, Cote d’
Ivoire, and the Democratic Republic of the Congo and
subsequently forced to work in agricultural labor. An NGO shelter
in Cote d’Ivoire reported caring for three Togolese children during
the year. Children from Benin and Ghana are recruited and
transported to Togo for forced labor. Trafficking offenders are
both women and men, and are often Togolese, Beninese, or
Nigerian. Some reports indicate Togolese women are fraudulently
recruited for employment in Lebanon, Saudi Arabia, the United
States, and Europe, where they are subsequently subjected to
domestic servitude and forced prostitution.

The Government of Togo does not fully comply with the minimum
standards for the elimination of trafficking; however, it is making
significant efforts to do so. The government sustained moderate
efforts to prosecute and punish trafficking offenders and protect
trafficking victims. However, it did not make progress in
completing and enacting legislation to prohibit trafficking crimes
committed against adults, and limited resources restricted the
government’s ability to accurately track prosecution and
protection data and disseminate it throughout government
ministries.

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?
Y
 
-  Maintain Records Over Time?
N
 
-  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"?
N
 
-  Criminalized Financing of Terrorism?
N
 
-  States Party to 1988 UN Convention?
Y
 
-  International Terrorism Financing Convention?
Y
 
Compliance with
FATF 40 + 9
recommendations
% Fully or Largely
Compliant
Date of last
Report
 
N/A
N/A
?
 
Ranking
2011
Ranking
2010
 
Corruption (Transparency International)
143 (out of
183)
134 (out
of 178)
?
Ease of doing business (World Bank)
162 (out of
183)
160 (out
of 183)
?
TOGO
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
Last Updated:   16 April 2012