Djibouti KYC, KYB & AML compliance checklist
A practical, source-linked checklist for implementing KYC, KYB and AML requirements in Djibouti.
- Last reviewed
- Last reviewed:
- Version
- Version 1.0
Direct answer
What does the Djibouti compliance checklist cover?
The Djibouti checklist translates primary KYC, KYB and AML rules into 11 control areas and 32 implementation checks. It identifies the relevant authorities, customer and beneficial-owner controls, reporting duties, recordkeeping expectations and evidence teams should retain.
Key regulatory facts
- FIU
- Agence Nationale de Renseignements Financiers (ANRF)
- Primary AML rule
- Law No. 106/AN/24, as amended by Law No. 178/AN/25
- Suspicion reporting
- Without delay to ANRF; later-arising suspicion is reported immediately
- Cash control
- Payments above DJF 1,000,000 are subject to control; confirm implementing reporting mechanics
- Core retention
- 5 years after relationship end or the last occasional transaction
- FATF status
- Not named on FATF public lists as at 19 June 2026
Implementation detail
Djibouti compliance requirements and actions
Open each control area to review the requirement, recommended implementation action, evidence to retain and the primary-source citation used by the research team.
01Scope, authorities, and licensingResolve the entity, activity and supervisor before launch.3 items+
Determine whether each activity is a reporting entity activity.
- Implementation action
- Map every entity, product, channel and agent to the financial-institution, VASP or DNFBP categories in Article 2-1-1 and identify ANRF and the competent sector supervisor.
- Evidence to retain
- Applicability memo, product map and accountable-owner register.
- Primary citation
- Law No. 106/AN/24 as amended, Article 2-1-1
Treat ANRF as Djibouti's financial intelligence unit.
- Implementation action
- Appoint required correspondents, obtain the current filing format and secure channel directly from ANRF, and test a controlled reporting path before operations begin.
- Evidence to retain
- Correspondent notice, channel test, procedure and access approvals.
- Primary citation
- Law No. 106/AN/24 as amended, Articles 3-2-1-1 to 3-3-4
Obtain authorisation before regulated financial activity.
- Implementation action
- Classify banking, payment, money-transfer, exchange, electronic-money, insurance and virtual-asset activities and obtain every required approval before launch.
- Evidence to retain
- Perimeter analysis, authority correspondence and licence register.
- Primary citation
- Law No. 119/AN/11/6th L; Instruction No. 2017-01; applicable sector rules
02Governance and risk assessmentThe programme must be documented, risk-based and independently tested.3 items+
Maintain a documented ML/TF risk assessment.
- Implementation action
- Assess customers, countries, products, services, transactions and distribution channels; update the assessment when risks or operations materially change.
- Evidence to retain
- Approved methodology, risk assessment, controls and version history.
- Primary citation
- Law No. 106/AN/24 as amended, Article 2-2-3
Maintain written controls and an empowered compliance function.
- Implementation action
- Assign senior accountability, confidential ANRF reporting authority, resources, staff screening, training and independent testing proportionate to risk.
- Evidence to retain
- Appointments, policies, training, testing and remediation log.
- Primary citation
- Law No. 106/AN/24 as amended, internal-control provisions
Assess new technology and virtual-asset exposure before use.
- Implementation action
- Identify and mitigate ML/TF/PF risks before launching a new product, channel, delivery mechanism or technology and before supporting virtual-asset activity.
- Evidence to retain
- Pre-launch assessment, approval, tests and residual-risk acceptance.
- Primary citation
- Law No. 106/AN/24 as amended, Articles 1-2-2 and 3-1-2-1
03Natural-person identificationCDD uses reliable, independent evidence and continues through the relationship.3 items+
Identify and verify customers and representatives.
- Implementation action
- Verify the customer using reliable independent documents, data or information; identify representatives and verify their authority.
- Evidence to retain
- Identity file, source provenance, mandate and verification result.
- Primary citation
- Law No. 106/AN/24 as amended, Articles 2-2-4 and 2-2-8
Understand purpose, nature and expected activity.
- Implementation action
- Record the relationship purpose, business nature, expected activity, counterparties, geography and source of funds sufficient for risk rating and monitoring.
- Evidence to retain
- Customer profile, expected-activity baseline and approval.
- Primary citation
- Law No. 106/AN/24 as amended, Articles 2-2-6 and 2-2-7
Do not proceed where mandatory CDD fails.
- Implementation action
- Do not execute, establish or continue the relationship when required CDD cannot be completed; file an STR where suspicion exists, without alerting the customer.
- Evidence to retain
- Decline or exit decision, investigation and restricted STR record.
- Primary citation
- Law No. 106/AN/24 as amended, Article 2-2-18
04KYB, registries, and beneficial ownershipRegistry evidence does not replace natural-person ownership and control analysis.3 items+
Verify legal existence, governance and authority.
- Implementation action
- Obtain current ODPIC or free-zone registration, constitutional, address, director, signatory, tax and licence evidence and reconcile inconsistencies.
- Evidence to retain
- Registry extract, statutes, powers, tax record and licence file.
- Primary citation
- Law No. 106/AN/24 as amended, Articles 2-2-4, 2-2-6 and 3-5-1-1
Identify and verify natural-person beneficial owners.
- Implementation action
- Trace ownership and control to the natural persons who ultimately own or control the customer; document the law's control and fallback analysis and verify each identified person.
- Evidence to retain
- Ownership chart, source records, control analysis and verified identities.
- Primary citation
- Law No. 106/AN/24 as amended, Article 2-2-4
Reconcile customer CDD with the national beneficial-owner register.
- Implementation action
- Obtain current beneficial-owner information, compare it with ODPIC or free-zone filings, investigate differences and ensure changes are notified within one month by the legal person.
- Evidence to retain
- Register evidence, discrepancy review and update record.
- Primary citation
- Law No. 106/AN/24 as amended, Articles 3-5-1-2 to 3-5-1-5
05PEPs, EDD, and remote onboardingHigher-risk and remote relationships require enhanced controls.3 items+
Detect PEP exposure in customers and beneficial owners.
- Implementation action
- Use risk-based systems to identify PEPs, direct family members and known close associates at onboarding and throughout the relationship.
- Evidence to retain
- Screening, relationship map, match decision and refresh log.
- Primary citation
- Law No. 106/AN/24 as amended, Article 2-2-20
Apply PEP approval, provenance and monitoring measures.
- Implementation action
- Obtain senior-management approval, establish source of wealth and source of funds, and conduct enhanced ongoing monitoring.
- Evidence to retain
- Approval, provenance analysis and monitoring plan.
- Primary citation
- Law No. 106/AN/24 as amended, Article 2-2-20
Control non-face-to-face risk.
- Implementation action
- Use reliable identity evidence and proportionate fraud, device, liveness and exception controls; document how remote verification meets AML and Digital Code requirements.
- Evidence to retain
- Remote-onboarding assessment, vendor review, tests and exceptions.
- Primary citation
- Law No. 106/AN/24 as amended, Article 2-2-4; 2025 Digital Code
06Monitoring and suspicious reportingANRF reporting is prompt, traceable and confidential.3 items+
Monitor activity against the current customer profile.
- Implementation action
- Examine complex, unusually large, linked or apparently purposeless activity and preserve the facts, analysis and reasoned conclusion.
- Evidence to retain
- Alerts, investigation, disposition and rule governance.
- Primary citation
- Law No. 106/AN/24 as amended, Articles 2-2-7 and 2-2-14
Report suspicious transactions and attempts without delay to ANRF.
- Implementation action
- File when required suspicion grounds arise; if suspicion emerges after execution, report immediately, and submit supplemental information without delay.
- Evidence to retain
- Decision chronology, report, receipt and supplemental-information log.
- Primary citation
- Law No. 106/AN/24 as amended, Article 3-3-1
Prevent tipping off.
- Implementation action
- Restrict access and do not disclose an STR, related transmission or ANRF analysis to the customer or unauthorised third parties.
- Evidence to retain
- Access logs, confidentiality procedure and training.
- Primary citation
- Law No. 106/AN/24 as amended, Article 3-4-2
07Payments, wires, thresholds, and agentsPayment controls preserve required data and distinguish controls from reporting duties.3 items+
Control cash and bearer payments above DJF 1,000,000.
- Implementation action
- Detect single or linked payments above the statutory control level and apply the current implementing control or reporting procedure confirmed with the competent authority; do not infer a universal automatic report from the threshold alone.
- Evidence to retain
- Detection logic, authority-confirmed procedure, review and filing where required.
- Primary citation
- Law No. 106/AN/24 as amended by Law No. 178/AN/25, Article 2-1-2
Route cross-border transfers above DJF 1,000,000 through an authorised institution.
- Implementation action
- Block or redirect covered transfers unless executed by or through an authorised credit or financial institution; retain required originator and beneficiary data.
- Evidence to retain
- Routing rule, message sample, exception workflow and authorisation evidence.
- Primary citation
- Law No. 106/AN/24 as amended, Article 2-1-3 and wire-transfer provisions
Retain accountability for agents and outsourcing.
- Implementation action
- Verify permissions, diligence providers, contract for security and record access, train agents, monitor performance and test retrieval.
- Evidence to retain
- Due diligence, contract, training, monitoring and retrieval test.
- Primary citation
- Instruction No. 2017-01 and applicable Banque Centrale de Djibouti rules
08Targeted financial sanctionsScreen, freeze and report under current national procedures.3 items+
Screen applicable UN and national designations.
- Implementation action
- Screen customers, beneficial owners, controllers, representatives and transactions at onboarding, list updates and before relevant execution.
- Evidence to retain
- List inventory, update logs, screening configuration and dispositions.
- Primary citation
- Law No. 104/AN/24; UN Security Council Consolidated List
Freeze covered funds and assets without prior notice.
- Implementation action
- Prevent prohibited movement or availability immediately upon a confirmed designation match and escalate through the competent national process.
- Evidence to retain
- Freeze procedure, timestamps, legal basis and authority communication.
- Primary citation
- Law No. 104/AN/24, targeted-financial-sanctions provisions
Govern matches, false positives and release.
- Implementation action
- Report confirmed matches through the current authority route, preserve confidentiality and release assets only on documented lawful authority.
- Evidence to retain
- Report, receipt, match rationale, authority instruction and reconciliation.
- Primary citation
- Law No. 104/AN/24; current implementing instructions
09Records and regulator accessRecords must reconstruct the customer, ownership, transaction and decision.3 items+
Retain CDD and relationship records for at least five years.
- Implementation action
- Retain identification, verification and relationship records for five years after relationship end or the last occasional transaction, subject to longer legal holds.
- Evidence to retain
- Schedule, configuration, archive sample and legal-hold log.
- Primary citation
- Law No. 106/AN/24 as amended, Article 2-2-19
Retain transaction and analysis records for at least five years.
- Implementation action
- Preserve transaction documents and information, examinations and analyses for five years from relationship end or the last occasional transaction and maintain reconstructability.
- Evidence to retain
- Transaction reconstruction, storage control and retrieval test.
- Primary citation
- Law No. 106/AN/24 as amended, Article 2-2-19
Respond securely to competent-authority requests.
- Implementation action
- Authenticate requests, protect STR confidentiality, produce reproducibly and log scope, timing and receipt.
- Evidence to retain
- Request, approval, production index and acknowledgement.
- Primary citation
- Law No. 106/AN/24 as amended, ANRF and supervisory powers
10Privacy, biometrics, and transfersThe 2025 Digital Code applies alongside AML secrecy and retention duties.3 items+
Document lawful, fair and accountable identity-data processing.
- Implementation action
- Map purposes, legal bases, notices, rights, recipients, security and retention; appoint a local representative where the extraterritorial rule requires one.
- Evidence to retain
- Data inventory, legal-basis assessment, notices and representative record.
- Primary citation
- 2025 Digital Code, Book I, Articles 2-6 and 54
Apply enhanced safeguards to biometric and sensitive data.
- Implementation action
- Document necessity and the permitted condition, minimise collection, restrict access, perform the required impact assessment and test security before use.
- Evidence to retain
- Impact assessment, security tests, access controls and approval.
- Primary citation
- 2025 Digital Code, Book I, sensitive-data and impact-assessment provisions
Control international transfers and incidents.
- Implementation action
- Document the lawful transfer mechanism and equivalent protection before export; implement current Commission notification and incident procedures without inventing a portal or deadline.
- Evidence to retain
- Transfer assessment, safeguards, incident plan and authority guidance.
- Primary citation
- 2025 Digital Code, Book I, international-transfer and security provisions
11Practical evidence packsMaintain concise packs that reproduce decisions and support supervisory access.2 items+
Maintain a reconstructable onboarding pack.
- Implementation action
- Bundle identity, KYB, beneficial ownership, screening, privacy, risk, approvals and exceptions under stable identifiers.
- Evidence to retain
- Complete sampled onboarding pack.
- Primary citation
- Operational control supporting Law No. 106/AN/24 as amended
Maintain a reconstructable monitoring and reporting pack.
- Implementation action
- Link transactions, alerts, analysis, approvals, reports and post-filing controls while protecting confidentiality.
- Evidence to retain
- Complete sampled case pack and access log.
- Primary citation
- Operational control supporting Law No. 106/AN/24 as amended, Articles 3-3-1 and 3-4-2
Primary-source register
12 sources used for this checklist
Use these links to verify the underlying legislation, regulator guidance, reporting procedures and international status statements.
- Law No. 178/AN/25 amending the AML/CFT/CPF frameworkOfficial Journal of Djibouti · Primary legislation
- Law No. 106/AN/24 - AML/CFT/CPFOfficial Journal of Djibouti · Primary legislation
- Law No. 104/AN/24 - terrorist financing and targeted sanctionsOfficial Journal of Djibouti · Primary legislation
- Decree No. 2024-314 implementing Law No. 106Official Journal of Djibouti · Primary decree
- Djibouti Digital CodeOfficial Journal of Djibouti · Primary legislation
- Djibouti mutual evaluationMENAFATF · Authoritative country assessment
- Djibouti country assessment pageFATF · Authoritative country status
- FATF black and grey listsFATF · Authoritative current status
- Banque Centrale de DjiboutiBanque Centrale de Djibouti · Official regulator guidance
- Instruction No. 2017-01 on electronic moneyBanque Centrale de Djibouti · Official regulatory instruction
- Law No. 119/AN/11 on credit institutions and financial auxiliariesBanque Centrale de Djibouti · Primary legislation
- United Nations Security Council consolidated sanctions listUnited Nations · Authoritative sanctions list
Direct answers
Djibouti KYC, KYB and AML questions
Who receives suspicious transaction reports?+
Djibouti's Agence Nationale de Renseignements Financiers (ANRF).
When is an STR filed?+
Without delay when the statutory suspicion grounds arise. If suspicion appears after execution, report immediately; supplemental information is submitted without delay.
Is there a cash threshold?+
Payments in cash or bearer instruments above DJF 1,000,000 are subject to control. Confirm the current implementing control or reporting procedure; the threshold alone should not be presented as a universal automatic report.
How is beneficial ownership handled?+
Identify and verify the natural persons who ultimately own or control the customer, and reconcile CDD with the national register administered through ODPIC and the free-zone authority.
How long are AML records retained?+
At least five years after the relationship ends or the last occasional transaction under Article 2-2-19, subject to longer legal holds.
Is Djibouti on a FATF public list?+
It was not named on FATF's high-risk or increased-monitoring lists current at 19 June 2026. The January 2025 MENAFATF evaluation nevertheless documents material weaknesses.
Does personal-data law apply?+
Yes. The 2025 Digital Code governs personal data, including extraterritorial processing, sensitive data and transfers. Confirm current Commission procedures before production use.
Can a payment or electronic-money product launch without approval?+
No. Classify the product under current Banque Centrale de Djibouti legislation and instructions and obtain every required approval before launch.
Research and review method
VOVE ID Compliance Research maps the regulatory perimeter, translates obligations into operational controls, links each material claim to a source and records the date and version of every review.
General regulatory information, not legal advice or a licence determination. Reviewed as applicable on 22 August 2026. Confirm reporting-entity status, ANRF filing specifications, objective-reporting instruments, operational beneficial-owner register access, sanctions procedures, Digital Code implementation and product licensing with the competent authority and qualified Djiboutian counsel before launch.