FATF Status

Togo is not on the FATF List of Countries that have been identified as having strategic AML deficiencies

Compliance with FATF Recommendations

The latest Mutual Evaluation Report relating to the implementation of anti-money laundering and counter-terrorist financing standards in Togo was undertaken in 2022. According to that Evaluation, Togo was deemed Compliant for 6 and Largely Compliant for 10 of the FATF 40 Recommendations. It was deemed Highly Effective for 0 and Substantially Effective for 0 of the Effectiveness & Technical Compliance ratings.

US Department of State Money Laundering assessment (INCSR)

Togo was deemed a ‘Monitored’ Jurisdiction by the US Department of State 2016 International Narcotics Control Strategy Report (INCSR). Key Findings from the report are as follows: -

Togo’s porous borders, susceptibility to corruption, and large informal sector make it vulnerable to illicit transshipments and small-scale money laundering. Most narcotics passing through Togo are destined for European markets. Drug and wildlife trafficking, trafficking in persons, corruption, misappropriation of funds, tax evasion, and smuggling are the major crimes in Togo. The country is used as a transit point for contraband ivory smuggling. The country’s small financial infrastructure, dominated by regional banks, makes it a less attractive venue for money laundering through financial institutions.

Rating                                                                           (100-Good / 0-Bad)

Transparency International Corruption Index                          31

World Governance Indicator – Control of Corruption             27

With an economically reform-minded government and modern transportation infrastructure, Togo’s steadily improving economic outlook offers opportunities for U.S. firms interested in doing business locally and in the sub-region. Even with a dip in growth due to the pandemic, Togo has sustained steady economic expansion since 2008 through reforms to encourage economic development and a better business environment. It ranked 97th on the Work Bank’s 2020 Doing Business report, an improvement of 59 places and the highest ranking in West Africa.

Current government policy is guided by the National Development Plan (PND) and an addendum policy roadmap for 2020-2025 that integrates business reforms and infrastructure projects designed to attract investment.

Togo launched its five-year PND in 2018, focusing on three axes. The plan’s first goal is to leverage the country’s geographic position by transforming Lome into a regional trading center and transport hub. Togo has already completed hundreds of kilometers of refurbished roadways, expanded and modernized the Port of Lome, and inaugurated in 2016 the new Lome international airport that conforms to international standards. The second goal is to increase agricultural production through agricultural centers (Agropoles) and increase manufacturing. The third goal is improving social development, including electrification of the country. The government seeks private sector investment to fulfill its PND goals and has had notable successes, including a new 2022 connection with the “Equiano” subsea cable owned by Google that will dramatically improve the quality of local broadband.

In January 2021, Prime Minister Victoire Tomégah-Dogbe presented a detailed developmental roadmap to extend, supplement and focus the goals of the PND for the remainder of the presidential term, which ends in 2025. The roadmap incorporates 42 specific projects, including universal access to identity documents and electricity; increased access to education, drinking water and sanitation; 20,000 new social housing units; a digital bank; construction of an industrial park around the port of Lome; and the extension of the road network. After a decade of sustained GDP growth of roughly 5% in non-pandemic years, Togo aspires to achieve 7.5% GDP growth by 2025.

Togo has also initiated numerous legal and institutional reforms to create a more favorable business environment, including digitalizing public services and revising the labor and investment codes. The Ministry of Investment has been a key advocate for business facilitation and partnering with the private sector since its creation in 2020.

Nevertheless, Togo must tackle several challenges to maintain its momentum. Challenges include an opaque legal system, lack of clear land titles, and government interference in various sectors. Corruption remains a common problem in Togo, especially for businesses. Often “donations” or “gratuities” result in expedited registrations, permits, and licenses, thus resulting in an unfair advantage for companies that engage in such practices. Although Togo has government bodies charged with combatting corruption, corruption-related charges are rarely brought or prosecuted. The government has made efforts to professionalize key institutions such as the Public Procurement Regulatory Authority (ARCOP), the Chamber of Commerce (CCIT), and the National Employment Agency (ANPE) including with new anti-corruption, ethics, and transparency measures.

The war in Ukraine has created further difficulties by feeding inflation and food insecurity.

The conflict has aggravated an already fragile post-Covid socio-economic situation and has caused disruptions in the supply chain for agricultural products and fertilizers. The main consequences are the rise in the prices of staple food and agricultural inputs, especially fertilizers which saw a price increase of 30% in less than a year.

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Country Links

Togo Financial Intelligence Unit (CENTIF Togo)

Central Bank of West African States (BCEAO)