Question 1

What is the current AML law in Côte d'Ivoire?

Accepted Answer

Ordinance No. 2023-875 of 23 November 2023 is the current national AML/CFT/CPF baseline. It was ratified by Law No. 2024-363 of 11 June 2024 and displaced contrary provisions of former Law No. 2016-992.

Question 2

How quickly must a suspicious transaction be reported?

Accepted Answer

Article 60 of Ordinance No. 2023-875 requires reporting immediately to CENTIF-CI. The obligation covers relevant funds, completed operations and attempted operations, and Article 61 generally requires reporting before execution where possible.

Question 3

What beneficial-owner threshold applies to financial institutions?

Accepted Answer

BCEAO Instruction No. 003-03-2025 Article 2 uses a more-than-25% test for company capital or voting rights and for interests in collective-investment structures, together with other-control and legal-arrangement tests. The percentage is not a safe harbour: institutions must still identify any natural person exercising ultimate control and use the senior-managing-official fallback only when no natural person is identified through ownership or other control.

Question 4

Can a fintech onboard customers fully remotely?

Accepted Answer

Yes, when it uses reliable electronic-identification means and satisfies BCEAO Instruction No. 003-03-2025. The first transaction must not occur before customer and applicable beneficial-owner verification, ambiguous evidence must be routed to in-person verification, and biometric processing requires prior ARTCI authorisation.

Question 5

Is Côte d'Ivoire on the FATF grey list?

Accepted Answer

Yes. Côte d'Ivoire was under increased monitoring in FATF's 13 February 2026 statement and remained listed on 19 June 2026. FATF then determined that the action plan was substantially completed and an on-site assessment was warranted, but formal removal had not yet been announced. FATF does not call for blanket EDD or de-risking solely because a jurisdiction is on this list.

Question 6

How long must AML records be kept?

Accepted Answer

Article 23 of Ordinance No. 2023-875 requires ten years for customer, KYC, risk and analysis records after account closure or relationship cessation, and ten years for transaction records after the transaction. Records must permit reconstruction of individual transactions.

Question 7

Does company registration authorise payment services?

Accepted Answer

No. Payment services require the applicable BCEAO authorisation under Instruction No. 001-01-2024. The BCEAO required unauthorised providers to cease from 1 May 2025, and its register reported nine authorised payment institutions in Côte d'Ivoire at 28 February 2026.

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