FATF AML Deficiency List
Non - Compliance with FATF MER Recommendations
Corruption Index (Transparency International & W.G.I.)
World Governance Indicators (Average Score)
US Dept of State Money Laundering assessment
Weakness in Government Legislation to combat Money Laundering
Cote D’Ivoire is not on the FATF List of Countries that have been identified as having strategic AML deficiencies
Compliance with FATF Recommendations
The initial Mutual Evaluation Report relating to the implementation of anti-money laundering and counter-terrorist financing standards in Cote D’Ivoire was undertaken in 2012. According to that Evaluation, Cote D’Ivoire was deemed Compliant for 0 and Largely Compliant for 7 of the FATF 40 + 9 Recommendations. It was Partially Compliant or Non-Compliant for 5 of the 6 of the Core Recommendations.
First follow-up report of Côte d’Ivoire
The first follow-up report of Côte d’Ivoire revealed that the country had made considerable progress in addressing the identified deficiencies in its AML/CFT regime. In particular, it has prepared a draft law on the suppression of terrorist acts, which had been forwarded to the General Secretariat of the Government in June 2013. Côte d’Ivoire also made some efforts to address deficiencies relating to Recommendations 13 and Special Recommendation IV and demonstrated the result of these efforts by providing statistics on suspicious transaction reports received by the FIU. The country also issued AML/CFT guidelines to financial institutions to ensure the effective implementation of customer due diligence measures. However, the country is yet to address the following outstanding deficiencies in the country’s AML/CFT system: non-criminalization of the full range of predicate offences of money laundering such as terrorism, financing of terrorist organizations and individual terrorists; migrant smuggling, insider trading and market manipulation; and speedy criminalization of self-laundering. Although Côte d’Ivoire had ratified 18 conventions on terrorism, the country has not adequately criminalized terrorist financing. It was observed that notwithstanding the confiscation of certain proceeds of crime, Côte d’Ivoire is yet to adopt a policy for the systematic and effective implementation of the legislation on freezing, seizure and confiscation of proceeds and instrumentalities of crime. Côte d’Ivoire was commended for the progress made considering its post- conflict situation, and was encouraged to urgently address the remaining deficiencies in its AML/CFT system to protect its economy from the vagaries of money launderers and financing of terrorism. Côte d’Ivoire was retained on Expedited Regular Follow-up, and was therefore directed to submit its second follow-up report to the Plenary in November 2014.
US Department of State Money Laundering assessment (INCSR)
Cote D’Ivoire was deemed a Jurisdiction of Concern by the US Department of State 2016 International Narcotics Control Strategy Report (INCSR). Key Findings from the report are as follows: -
Since the end of the post-electoral crisis in April 2011, the political situation in Cote d’Ivoire has stabilized. The country held a peaceful and credible presidential election on October 25, 2015, which turned a symbolic page on its conflict-ridden past. Despite a more stable political environment and increased prosecutions in 2015, Ivoirians continue to be involved in regional criminal activities, such as the smuggling of consumer goods and agricultural products, and in the subsequent laundering of the proceeds. Smuggling over Cote d’Ivoire’s porous borders, motivated in part by a desire to avoid duties or taxes or to sell goods at a higher profit, generates illicit funds that are primarily laundered via informal value transfer systems, such as money service businesses or exchange houses, and via mobile telephone payments or transfers (M- Payments).
Many Ivoirians use informal cash couriers, money and value transfer services (MVTS), hawaladars, and goods transportation companies to transfer funds domestically and within the region. There is no regulation of domestic informal MVTS.
There are concerns about the increase in cyber theft through online commercial transactions. In addition, Ivoirian authorities believe criminal enterprises use the formal banking system, as well as the used car, real estate, and counterfeit pharmaceutical drug industries to launder funds. The use of Ivoirian territory as a transshipment point for drugs from South America to Europe has decreased with the creation of new routes by drug traffickers after the Arab spring and tightened airport security. Hezbollah is present in Cote d’Ivoire and conducts fundraising activities, mostly among the large Lebanese expatriate community in the country.
Cote d’Ivoire still remains under sanctions imposed by the UN Security Council (UNSC) stemming from the civil war and political/military crisis period. On April 29, 2014, the UNSC lifted the ban on exporting rough diamonds from Cote d’Ivoire and partially lifted the arms embargo, allowing the purchase of small-caliber weapons while still requiring Cote d’Ivoire to seek a UNSC exemption for purchases of certain other arms. Additionally, several officials of the former regime are subject to targeted financial sanctions by the United States, the UK, and the EU. The government continues to work toward the goal of having the international sanctions lifted for some of these officials. The country was found Kimberley Process compliant in November 2013, and legal exportation of diamonds under the Kimberley Process began in March 2015.
There are no longer any international sanctions in place.
BRIBERY & CORRUPTION
Rating (100-Good / 0-Bad)
Transparency International Corruption Index 36
World Governance Indicator – Control of Corruption 34
Cote d'Ivoire is heavily dependent on agriculture and related activities, which engage roughly two-thirds of the population. Cote d'Ivoire is the world's largest producer and exporter of cocoa beans and a significant producer and exporter of coffee and palm oil. Consequently, the economy is highly sensitive to fluctuations in international prices for these products and in climatic conditions. Cocoa, oil, and coffee are the country's top export revenue earners, but the country is also mining gold.
Following the end of more than a decade of civil conflict in 2011, Cote d’Ivoire has experienced a boom in foreign investment and economic growth. In June 2012, the IMF and the World Bank announced $4.4 billion in debt relief for Cote d'Ivoire under the Highly Indebted Poor Countries Initiative.
Agriculture - products:
coffee, cocoa beans, bananas, palm kernels, corn, rice, cassava (manioc, tapioca), sweet potatoes, sugar, cotton, rubber; timber
foodstuffs, beverages; wood products, oil refining, gold mining, truck and bus assembly, textiles, fertilizer, building materials, electricity
Exports - commodities:
cocoa, coffee, timber, petroleum, cotton, bananas, pineapples, palm oil, fish
Exports - partners:
US 8.5%, Netherlands 6.2%, France 5.6%, Germany 5.6%, Nigeria 5.5%, Burkina Faso 5.5%, Belgium 5.3%, India 4.6%, Ghana 4.4%, Switzerland 4.1% (2015)
Imports - commodities:
fuel, capital equipment, foodstuffs
Imports - partners:
Nigeria 21.9%, China 14.4%, France 11.4%, Bahamas, The 5% (2015)
Cote d’Ivoire offers fertile soil for U.S. investment and the Ivoirian Government is keen to deepen economic cooperation with the United States. Following a credible and peaceful election in October 2015 – in which President Ouattara was overwhelmingly reelected to a second term – the country has preserved its post-2011 political stability and is focusing intently on economic growth in order to become an “emerging” economy by 2020. Cote d’Ivoire continues its efforts to consolidate its place as an economic engine for West Africa by making its economy attractive to both domestic and foreign investors through a $49 billion 2016-2020 National Development Program. It is ranked as the sixth fastest growing economy in the world based on World Bank forecasts. The changed environment led the African Development Bank (AfDB) to return its headquarters to Abidjan in 2014, a move that subsequently prompted a number of major international businesses to follow suit.
The main drivers of this impressive sustained growth are public and private investments in infrastructure, including an extension of Abidjan’s port, construction, and natural resource extraction. The GOCI and private industry have also made investments in agriculture and agricultural product value-added processing. Cote d’Ivoire is ranked 142 of the 189 economies in the 2016 World Banks’s Doing Business Report, but was among the top 10 reformers in both 2014 and 2015. These impressive figures highlight the GOCI’s notable progress in improving the business environment. Improvements include the implementation of a single user identification number for business creation, online submission of complaints to the Commercial Court of Abidjan, publication of rulings from the Commercial Court, and electronic land registration.
The GOCI’s impressive track record also includes the implementation of new codes on investment, electricity, and mining. The new mining code was a key factor for the country to accede to both the Kimberley Process and the Extractive Industries Transparency Initiative (EITI). In 2014, the UN lifted its diamond embargo, and in March, 2015, Cote d’Ivoire began to export Kimberley Process Certified diamonds. After passing the minimum number of Millennium Challenge Corporation (MCC) Indicators, Cote d’Ivoire became eligible for an MCC Threshold program in December 2014 and was found eligible for an MCC Compact in December 2015. The GOCI’s efforts to ensure good governance and transparency and to fight against corruption contributed to its MCC eligibility and increased foreign direct investments. Much of this work is spearheaded by the High Authority for Good Governance, an anti-corruption watchdog the Ouattara Administration created in 2013.
The number of business startups and private investments continue to increase. In 2015, a total of 9,534 businesses were created, up 47 percent from 2014. The government realizes that while registering a business is easy, significant hurdles remain before a company can open its doors, and it is working diligently to address them. For example, the government has improved access to industrial land with the development of the new PK24 industrial zone.
Additionally, e-commerce is now beginning. As a regional economic hub, Cote d’Ivoire hosted the 2016 Africa CEO Forum to emphasize its focus on the private sector in fostering growth. In 2015, Cote d’Ivoire re-launched its International Agriculture and Livestock Exhibition to promote sustainable agriculture and attract foreign investors in this important sector. U.S. businesses were well represented at the 2014 Invest in Cote d’Ivoire (ICI) Forum – some of whom have since returned to pursue business opportunities. For the region, Cote d’Ivoire offers a relatively well-developed road infrastructure, the second largest port in West Africa, and a modern airport with a reliable national airline, Air Cote d’Ivoire, which services all of the major capital cities in the region.
The most fruitful areas of investment for U.S. businesses are in oil and gas exploration and production, housing construction, power generation, and the mining industry. Opportunities also exist in agribusiness projects such as corn and rice production, as well as manufacturing ventures to add value to commodities such as cocoa, cashews, and coffee. The GOCI announced in March 2015 an ambitious plan to dramatically increase the amount of processed cocoa it exports. Textile manufacturing, especially the production of traditional Ivoirian cotton cloth and products made from that cloth, are also potential areas of investment.
Despite the country’s impressive economic track record over the past few years, challenges continue to exist for investors. Improvements in the national security situation over the past four years are evident, however progress on national reconciliation and impartial justice has gone slowly and much hard work remains. Islamist militant groups active in the Sahel also pose a threat in the region. Cote d’Ivoire suffered its first terrorist attack on March 13, 2016 on the beaches of Grand Bassam, for which Al Qaeda in the Islamic Maghreb subsequently claimed responsibility. The Ivoirian forces responded very quickly, however, showing that its capacity has improved over the past few years.
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