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title: "Ivory Coast / UEMOA (CI) — Financial-Integrity Intelligence · Sentinel"
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description: "Financial integrity intelligence for Ivory Coast (UEMOA bloc) (CI): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings."
generated_at: 2026-11-08T19:35:25Z
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# Ivory Coast / UEMOA (CI) — Financial-Integrity Intelligence · Sentinel

Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above &ldquo;Probable&rdquo; until stronger sources are retrieved.

Financial Integrity Monitor

# Ivory Coast / UEMOA CI

Domains covered

8 of 8

Sources

178

Role actions

8

Horizon <90d

2

Jurisdiction profile

FATF status: Grey-List Tier: B Risk direction: Improving Enablement vs enforcement: Mixed

AML/CFT/CPF is governed by Ordonnance 2023-875 (AML/CFT/PF Order), transposing the 2023 UEMOA uniform AML/CFT law and replacing Law 2016-992. More CENTIF is the FIU; HABG (anti-corruption) and the Agence de gestion et de recouvrement des avoirs criminels (asset recovery) complete the institutional architecture, all nested within the eight-state UEMOA/BCEAO monetary union. Following its 2023 GIABA Mutual Evaluation, Côte d&#x27;Ivoire entered FATF increased monitoring in October 2024 and has since completed two Enhanced Follow-Up Reports upgrading technical compliance.

Key deficiencies

- Weak conversion of terrorist-financing investigations into prosecutions and convictions
- Incomplete verification, access, and sanctioning of beneficial ownership violations for legal persons
- Under-implemented risk-based supervision of financial institutions and DNFBPs
- Limited use of financial intelligence by law enforcement and weak FIU disseminations
- Porous, cash-intensive borders enabling cocoa and gold trade-based laundering

Recent developments (18m)

- June 2026 FATF Plenary: initial determination that CI&#x27;s action plan is substantially complete, on-site assessment warranted
- October 2025 and February 2026 FATF progress reviews confirming BO/TFS reform steps
- EU Commission added Côte d&#x27;Ivoire to its high-risk third country list (June 2025)
- UK HM Treasury listed Côte d&#x27;Ivoire as a High-Risk Third Country under MLR reg. 33 (Feb/June 2026 notices)
- GIABA 2nd Enhanced Follow-Up Report (May 2025) re-rated 12 FATF Recommendations upward

Brief

## Lead signal

#### Lead Signal

The Financial Action Task Force removed Cote d&#x27;Ivoire from its list of jurisdictions under increased monitoring at the 28-30 October 2026 Plenary, closing out the action plan the country had been working against since October 2024. FATF&#x27;s own statement frames the removal as recognition of significant progress in strengthening the countrys AML/CFT regime, citing improvements across institutional, legislative, regulatory and operational dimensions. This is a confirmed, structural development rather than an isolated event: it reflects a cumulative reform trajectory rather than a single enforcement action or a one-off legislative fix, and it changes the baseline AML/CFT risk posture that counterparties and correspondent institutions apply to the jurisdiction going forward.

Read full brief

#### Lead Signal

The Financial Action Task Force removed Cote d&#x27;Ivoire from its list of jurisdictions under increased monitoring at the 28-30 October 2026 Plenary, closing out the action plan the country had been working against since October 2024. FATF&#x27;s own statement frames the removal as recognition of significant progress in strengthening the countrys AML/CFT regime, citing improvements across institutional, legislative, regulatory and operational dimensions. This is a confirmed, structural development rather than an isolated event: it reflects a cumulative reform trajectory rather than a single enforcement action or a one-off legislative fix, and it changes the baseline AML/CFT risk posture that counterparties and correspondent institutions apply to the jurisdiction going forward.

Among the specific improvements FATF credits as part of the closure is enhanced verification of and access to basic and beneficial ownership information. This is a probable rather than confirmed element of the picture: the FATF statement characterises the improvement, but no beneficial-ownership registry instrument for Cote d&#x27;Ivoire was independently retrieved this cycle. The gap matters because beneficial-ownership transparency is one of the areas most prone to a gap between a stated improvement and a verifiable, independently-sourced instrument, and it is the item most likely to need confirmation from primary material in a future cycle.

#### Other Developments

Follow-up reporting has not yet caught up with the delisting. The Inter-Governmental Action Group against Money Laundering in West Africa, the FATF-style regional body responsible for ongoing supervision of Cote d&#x27;Ivoire&#x27;s AML/CFT effectiveness, last published a Follow-Up Report on 31 May 2026 -- a date that precedes the October 2026 Plenary decision. That report has not yet been updated to reflect the delisting. This is not itself a finding of concern; it is a sequencing gap that is expected to close as the regional body&#x27;s reporting cycle catches up with the FATF decision, and it is the principal item to watch in the period ahead.

The government welcomed the decision as validation of a multi-year reform programme. Press reporting attributes to Cote d&#x27;Ivoire&#x27;s Ministry of Economy, Finance and Budget a public statement welcoming the FATF decision as reflecting institutional, legislative, regulatory and operational reform. This corroborates the FATF&#x27;s own framing from the jurisdiction side, though the underlying sourcing for this specific claim is a secondary press report rather than a primary government statement text.

#### Cross-Monitor Connections

The reduction in Cote d&#x27;Ivoire&#x27;s AML/CFT risk profile has a direct read-across to counterparty and sovereign risk assessment: a lower increased-monitoring designation typically eases the enhanced due diligence burden that banks and other obliged entities apply to counterparties and correspondent relationships touching the jurisdiction, with knock-on relevance for how banking and sovereign counterparty risk is weighed elsewhere in the group&#x27;s monitoring. Separately, the payments-side regulatory activity visible in Cote d&#x27;Ivoire and the wider West African Economic and Monetary Union this cycle -- tightening of e-money prudential and backing-asset rules alongside a mandatory interoperable-routing regime -- sits adjacent to, but outside, the AML/CFT delisting story; it is tracked independently in payments-focused coverage and is not treated here as part of the FATF action-plan narrative.

#### Outlook

The item to watch next is whether GIABA&#x27;s follow-up reporting is updated to reflect the October 2026 delisting, and whether any primary beneficial-ownership registry or verification instrument for Cote d&#x27;Ivoire becomes independently available to confirm the specific improvement FATF credited. Absent a reversal signal, the removal from increased monitoring is likely to be treated by counterparties as a durable, if recent, change in baseline risk rather than a provisional one, though formal confirmation through updated regional reporting would further solidify that reading.

Earlier periodic briefs (9) 8 Nov 2026 · fim-2026-11-08

#### Lead Signal

The Financial Action Task Force removed Cote d&#x27;Ivoire from its list of jurisdictions under increased monitoring at the 28-30 October 2026 Plenary, closing out the action plan the country had been working against since October 2024. FATF&#x27;s own statement frames the removal as recognition of significant progress in strengthening the countrys AML/CFT regime, citing improvements across institutional, legislative, regulatory and operational dimensions. This is a confirmed, structural development rather than an isolated event: it reflects a cumulative reform trajectory rather than a single enforcement action or a one-off legislative fix, and it changes the baseline AML/CFT risk posture that counterparties and correspondent institutions apply to the jurisdiction going forward.

Among the specific improvements FATF credits as part of the closure is enhanced verification of and access to basic and beneficial ownership information. This is a probable rather than confirmed element of the picture: the FATF statement characterises the improvement, but no beneficial-ownership registry instrument for Cote d&#x27;Ivoire was independently retrieved. The gap matters because beneficial-ownership transparency is one of the areas most prone to a gap between a stated improvement and a verifiable, independently-sourced instrument, and it is the item most likely to need confirmation from primary material in a future cycle.

#### Other Developments

Follow-up reporting has not yet caught up with the delisting. The Inter-Governmental Action Group against Money Laundering in West Africa, the FATF-style regional body responsible for ongoing supervision of Cote d&#x27;Ivoire&#x27;s AML/CFT effectiveness, last published a Follow-Up Report on 31 May 2026 -- a date that precedes the October 2026 Plenary decision. That report has not yet been updated to reflect the delisting. This is not itself a finding of concern; it is a sequencing gap that is expected to close as the regional body&#x27;s reporting cycle catches up with the FATF decision, and it is the principal item to watch in the period ahead.

The government welcomed the decision as validation of a multi-year reform programme. Press reporting attributes to Cote d&#x27;Ivoire&#x27;s Ministry of Economy, Finance and Budget a public statement welcoming the FATF decision as reflecting institutional, legislative, regulatory and operational reform. This corroborates the FATF&#x27;s own framing from the jurisdiction side, though the underlying sourcing for this specific claim is a secondary press report rather than a primary government statement text.

#### Cross-Monitor Connections

The reduction in Cote d&#x27;Ivoire&#x27;s AML/CFT risk profile has a direct read-across to counterparty and sovereign risk assessment: a lower increased-monitoring designation typically eases the enhanced due diligence burden that banks and other obliged entities apply to counterparties and correspondent relationships touching the jurisdiction, with knock-on relevance for how banking and sovereign counterparty risk is weighed elsewhere in the group&#x27;s monitoring. Separately, the payments-side regulatory activity visible in Cote d&#x27;Ivoire and the wider West African Economic and Monetary Union -- tightening of e-money prudential and backing-asset rules alongside a mandatory interoperable-routing regime -- sits adjacent to, but outside, the AML/CFT delisting story; it is tracked independently in payments-focused coverage and is not treated here as part of the FATF action-plan narrative.

#### Outlook

The item to watch next is whether GIABA&#x27;s follow-up reporting is updated to reflect the October 2026 delisting, and whether any primary beneficial-ownership registry or verification instrument for Cote d&#x27;Ivoire becomes independently available to confirm the specific improvement FATF credited. Absent a reversal signal, the removal from increased monitoring is likely to be treated by counterparties as a durable, if recent, change in baseline risk rather than a provisional one, though formal confirmation through updated regional reporting would further solidify that reading.

3 Nov 2026 · fim-2026-11-01

#### Lead Signal

The Financial Action Task Force removed Cote d&#x27;Ivoire from its list of jurisdictions under increased monitoring at the close of its 28-30 October 2026 Paris plenary, alongside Bulgaria, the Democratic Republic of the Congo and Monaco. Cote d&#x27;Ivoire had carried the increased-monitoring designation since October 2024 and exits following a twenty-four month action plan that FATF&#x27;s own June 2026 statement had already described as substantially completed. The overall list fell from twenty-two to eighteen jurisdictions this plenary with no new additions, and Cote d&#x27;Ivoire will continue working with GIABA, the FATF-style regional body for West Africa, to sustain the improvements that underpinned its exit. This is an architecture-level finding rather than a single enforcement event: the reforms cited by FATF in its June 2026 determination included improved verification of and access to basic and beneficial-ownership information on legal persons, with sanctions attached for non-compliance, pointing to a structural strengthening of the corporate-transparency layer that sits beneath the anti-money-laundering and counter-terrorist-financing regime rather than an isolated procedural fix.

The exit, however, does not resolve Cote d&#x27;Ivoire&#x27;s international standing in full. The jurisdiction remains on the European Commission&#x27;s list of high-risk third countries, a designation that has been in force since 5 August 2025 and that triggers enhanced due diligence obligations for obliged entities dealing with Ivorian counterparties regardless of the FATF decision. Press commentary in the days following the FATF announcement raised the possibility that the EU listing could be reconsidered, but no European Commission primary source confirming a review timetable was located. Cote d&#x27;Ivoire therefore sits, for the time being, as a live case of divergence between the FATF and EU list architectures: delisted by one, still enhanced-due-diligence-designated by the other.

#### Other Developments

A sandbox that excludes the asset class it might have embraced. The Banque Centrale des Etats de l&#x27;Afrique de l&#x27;Ouest opened a call for applications on 14 October 2026 for the first cohort of its new Laboratoire d&#x27;Innovation Financiere, open across all eight UEMOA member states including Cote d&#x27;Ivoire until 30 November 2026. The call&#x27;s own text explicitly excludes crypto-asset projects from consideration. Read against BCEAO&#x27;s continuing non-recognition of crypto-assets as legal tender across the union, the sandbox reaffirms rather than closes the regulatory vacuum for digital assets in the zone: UEMOA gains a formal supervisory-innovation channel for financial technology generally, while the crypto segment specifically remains outside any dedicated regulatory perimeter.

The statutory foundation beneath the FATF exit. Ordonnance n 2023-875 du 23 novembre 2023 introduced an autonomous money-laundering offence into Ivorian law, independent of the need to prove a predicate offence, and transposed UEMOA Directive n 01/2023/CM/UEMOA. This instrument underpins the current mandate of CENTIF, the national financial-intelligence unit, and is among the legal reforms FATF cites as part of the architecture supporting Cote d&#x27;Ivoire&#x27;s grey-list exit. It remains in force.

#### Cross-Monitor Connections

The beneficial-ownership verification improvements cited in the FATF determination carry a direct read-through for corporate-transparency and state-capture analysis: a jurisdiction strengthening the traceability of legal-person ownership structures changes the operating conditions for shell-company layering that conflict-finance and state-capture typologies elsewhere in the fleet depend on. The continuing exclusion of crypto-assets from BCEAO&#x27;s innovation sandbox is similarly relevant to digital-asset and financial-innovation tracking across the region: a formal fintech sandbox that pointedly carves out crypto signals a central bank distinguishing between innovation it will supervise and an asset class it still will not recognise, a distinction worth carrying into any regional digital-asset exposure assessment.

#### Outlook

The immediate architecture question is whether the European Commission&#x27;s high-risk third-country listing of Cote d&#x27;Ivoire will be revisited following the FATF exit. Press sources floated the possibility in the days after the October plenary, but as no Commission primary source or review timetable has been identified, the designation should be treated as standing and in force unless and until a Commission document says otherwise. Firms with Ivorian exposure should expect enhanced due diligence obligations under the EU framework to persist independently of the improved FATF standing. On the digital-asset side, the BCEAO sandbox&#x27;s November 2026 application window closes without a crypto-asset track, so no near-term change to UEMOA&#x27;s crypto regulatory vacuum is in view from that channel; any future shift would need to come from a separate BCEAO or UEMOA-level instrument addressing crypto-assets directly, not from the innovation-lab mechanism now in place.

18 Oct 2026 · fim-2026-10-18

#### Lead Signal

Côte d&#x27;Ivoire&#x27;s path off the FATF grey list reached a procedural milestone this period. At its June 2026 Plenary, FATF made an initial determination that Côte d&#x27;Ivoire had substantially completed its AML/CFT action plan and warranted an on-site assessment; an on-site team reportedly visited Abidjan from 8 to 10 September 2026, and the formal exit verdict is expected at the FATF plenary in Paris, scheduled for 26 to 30 October 2026. Côte d&#x27;Ivoire has been on the grey list since October 2024, and Ivorian judicial authorities are reported to have opened more than 1,000 money-laundering case files as part of an accelerated grey-list exit strategy. Separately, GIABA&#x27;s June 2026 3rd Enhanced Follow-Up Report re-rated eleven FATF Recommendations upward for Côte d&#x27;Ivoire, including an upgrade of Recommendation 24 (beneficial ownership of legal persons) from partially-compliant to largely-compliant; the country&#x27;s overall rating profile now stands at six recommendations rated compliant, twenty-four largely-compliant, seven partially-compliant and three still non-compliant.

#### Other Developments

BCEAO&#x27;s new sandbox excludes crypto. The Banque Centrale des Etats de l&#x27;Afrique de l&#x27;Ouest opened applications, 14 October through 30 November 2026, for the first cohort of its Financial Innovation Laboratory regulatory sandbox, open to UEMOA fintechs and licensed financial institutions. Crypto-assets are explicitly excluded from the testing scope, and a successful test does not confer authorisation — a deliberate regulatory-perimeter decision that keeps digital assets outside the region&#x27;s first formal innovation-testing structure. Beneficial ownership compliance improving. The GIABA follow-up upgrade of Recommendation 24 reflects a structural improvement in how Côte d&#x27;Ivoire&#x27;s beneficial-ownership regime for legal persons is assessed, moving from partially- to largely-compliant status in the June 2026 report.

#### Cross-Monitor Connections

The BCEAO sandbox exclusion of crypto-assets is the same event tracked by the crypto monitor as confirmation that no licensing pathway exists for crypto-asset service providers in the UEMOA zone, and by world-payments as a fintech-sector regulatory-innovation development; here it is read as evidence of a central bank deliberately keeping a higher-risk asset class outside its first formal compliance-testing structure, consistent with a grey-listed jurisdiction&#x27;s incentive to avoid adding supervisory complexity while under FATF review. The pending FATF exit verdict, if favourable, would be expected to ease correspondent-banking and enhanced-due-diligence friction that the advennt monitor notes as relevant to gambling-sector payment flows into and out of Côte d&#x27;Ivoire.

#### Outlook

The FATF plenary scheduled for 26 to 30 October 2026 in Paris is the near-term event that will determine whether Côte d&#x27;Ivoire exits grey-list status after two years of enhanced monitoring since October 2024. A favourable verdict would be the most consequential single development for the jurisdiction&#x27;s integrity profile this year, easing the enhanced-due-diligence treatment that FATF grey-list status currently triggers for counterparties globally. Should the verdict be deferred or adverse, the over-1,000 opened money-laundering case files and the GIABA Recommendation upgrades would remain as evidence of forward momentum even without a formal exit.

11 Oct 2026 · fim-2026-10-11

#### Lead Signal

Côte d&#x27;Ivoire&#x27;s financial-integrity picture this cycle is dominated not by a sanctions or AML-architecture event but by commercial activity in the fintech and payments sector, within the trailing twelve-month D8 window. Wave Mobile Money&#x27;s Ivorian subsidiary launched a fully licensed commercial bank, Wave Bank Africa S.A., in Abidjan, capitalised with 20 billion FCFA (approximately 32 million dollars) in start-up capital. The launch followed a 117 million euro debt-financing round closed in June 2025. Separately, Côte d&#x27;Ivoire&#x27;s state investment fund, the Caisse des Dépôts et Consignations (CDC-CI), confirmed on 31 December 2025 that it had acquired a stake in the Abidjan fintech Green Pay, alongside existing shareholder Orange Côte d&#x27;Ivoire Participations. Neither deal&#x27;s full terms are publicly disclosed, and the Green Pay transaction&#x27;s amount has not been disclosed at all.

#### Other Developments

The standing AML/CFT architecture remains unchanged in substance. Ordonnance n°2023-875 of 23 November 2023 continues to govern Côte d&#x27;Ivoire&#x27;s AML/CFT/PF regime, transposing the UEMOA uniform AML/CFT law and repealing the prior 2016 statute. It designates casinos, including internet casinos, and gaming establishments including the national lottery, as obliged entities (EPNFD/DNFBP) subject to the regime. No amendment to this ordinance or its 2024 supporting instruments was located this cycle. The FATF grey-list trajectory continues to move toward possible exit. In June 2026, FATF determined that Côte d&#x27;Ivoire had substantially completed its action plan and authorised an on-site assessment to verify that reforms had been implemented and were sustainable; the next Plenary, scheduled in Paris for 26 to 30 October 2026, is the earliest point at which removal from the list of jurisdictions under increased monitoring could be decided.

#### Cross-Monitor Connections

The Wave Bank Africa and Green Pay transactions are payments-infrastructure events that the world-payments monitor is tracking in parallel as commercial-intelligence developments; this brief records them here only insofar as they bear on the financial-integrity picture, as new regulated entities entering the Ivorian financial system under the existing AML/CFT designation regime. The FATF grey-list trajectory connects directly to the advennt gambling monitor&#x27;s standing AML/CFT coverage, since gambling operators remain among the designated obliged entities under Ordonnance n°2023-875.

#### Outlook

The late-October 2026 FATF Plenary is the clearest date to watch: a removal decision would mark the first material change to Côte d&#x27;Ivoire&#x27;s grey-list status since October 2024 and would reduce the enhanced-due-diligence burden that counterparties currently apply to Ivorian financial relationships. On the commercial side, continued fintech consolidation in Abidjan, evidenced by Wave&#x27;s banking-licence conversion and CDC-CI&#x27;s continued stake-building in Green Pay, suggests the state and private capital are both positioning around the same licensed-financial-institution model ahead of any grey-list exit.

28 Sep 2026 · fim-2026-09-28

#### Lead Signal

The most consequential financial-integrity signal touching Cote d&#x27;Ivoire this cycle sits in Crypto, Digital Assets, and Financial Innovation. BCEAO reaffirmed in July 2026 a non-recognition and caution posture on crypto-assets across the UEMOA zone, including Cote d&#x27;Ivoire, stating publicly that crypto-assets are not money and are not regulated. Alongside that reaffirmation, BCEAO formed C-CRYPTO, a committee tasked with drafting a regional crypto-asset regulatory framework; no such framework had been adopted region-wide as of August 2026 commentary. This is an enablement-side signal as much as an enforcement-side one: the absence of a binding framework, paired with a caution statement rather than a prohibition, leaves crypto activity in the zone in a regulatory gap that a committee has been stood up to close but has not yet closed.

#### Other Developments

Cote d&#x27;Ivoire&#x27;s FATF grey-list status persists with credited progress. The FATF&#x27;s 13 February 2026 plenary statement records that, since Cote d&#x27;Ivoire&#x27;s October 2024 political commitment, the country has improved risk-based supervision and financial-intelligence-unit dissemination, and has demonstrated a sustained increase in terrorist-financing investigations. Cote d&#x27;Ivoire must still demonstrate a sustained increase in money-laundering investigations and prosecutions to exit increased monitoring. In parallel, GIABA&#x27;s publication registry lists a third Enhanced Follow-Up Report and a first report under a second-round mutual evaluation cycle for Cote d&#x27;Ivoire in 2026; the substantive content of these reports was not retrieved this cycle, so their findings cannot yet be summarised.

Cambodia&#x27;s own grey-list exposure is rising, illustrating a comparator risk pattern. Cambodia&#x27;s central-bank governor warned in January 2026 that persistent links between illegal casino operations, cross-border scam centres and money-laundering risk could trigger a third FATF grey-list placement for that country; authorities there intensified crackdowns on illegal online casinos in response. This is not a Cote d&#x27;Ivoire development but is tracked as a parallel case of grey-list risk driven by a different underlying typology.

#### Cross-Monitor Connections

BCEAO&#x27;s crypto caution posture and the C-CRYPTO committee&#x27;s drafting mandate connect directly to the crypto monitor&#x27;s own tracking of the same regulatory gap in Cote d&#x27;Ivoire, and to world-payments&#x27; tracking of BCEAO&#x27;s broader payments-infrastructure agenda in the UEMOA zone; this financial-integrity brief foregrounds the money-laundering and terrorist-financing exposure created by an unregulated crypto corridor operating alongside a grey-listed jurisdiction, a combination that other monitors are better placed to address from a licensing or payments-infrastructure angle respectively.

#### Outlook

Watch for whether GIABA&#x27;s substantive report content, once retrieved, alters the assessment of Cote d&#x27;Ivoire&#x27;s progress toward FATF grey-list exit, and for whether C-CRYPTO produces draft regulatory text that would close the crypto-specific gap BCEAO&#x27;s caution statement currently leaves open. A jurisdiction combining continued grey-list status with an unregulated crypto corridor carries a structurally elevated illicit-finance exposure until either the FATF review cycle resolves in Cote d&#x27;Ivoire&#x27;s favour or a binding crypto framework is adopted, whichever comes first.

22 Sep 2026 · fim-2026-09-22

#### Lead Signal

BCEAO&#x27;s central bank leadership confirmed in July 2026 that the West African Monetary Union, including Cote d&#x27;Ivoire, continues to operate without a formal crypto-asset regulatory framework, even as a dedicated C-CRYPTO drafting committee, formed following an 8 May 2026 Dakar conference, works on regional rules with no published timeline. This is the standout development for Cote d&#x27;Ivoire this cycle: a structural regulatory gap in an eight-member currency union of which Cote d&#x27;Ivoire is a founding participant, persisting even as regional institutional attention to the topic visibly increases.

#### Other Developments

FATF grey-list status persists. Cote d&#x27;Ivoire has remained on the FATF list of Jurisdictions Under Increased Monitoring continuously since October 2024, confirmed across both the 13 February 2026 and 19 June 2026 plenary lists. This sustained status raises heightened-due-diligence expectations for correspondent banks and international counterparties dealing with Ivorian entities.

GIABA remediation trajectory continues. GIABA adopted a 3rd Enhanced Follow-Up Report for Cote d&#x27;Ivoire in 2026, continuing a remediation process that began with the 2023 Mutual Evaluation and saw nine FATF Recommendations re-rated in the 1st Follow-Up Report in 2024, three to Compliant and six to Largely Compliant. Only title-level T1 confirmation of the 3rd report was available this cycle; its substantive content was not independently opened.

FIU architecture remains secondary-sourced. CENTIF-CI continues to be described in secondary commentary as Cote d&#x27;Ivoire&#x27;s designated national financial intelligence unit, with the UEMOA Banking Commission providing prudential oversight and GIABA the regional assessment layer. No primary-source confirmation of this architecture was retrieved this cycle, so it is treated with caution.

Historical sanctions position remains dormant. Cote d&#x27;Ivoire&#x27;s country-level United States sanctions program under 31 CFR Part 543 was terminated in 2016 and formally removed from the Code of Federal Regulations in 2017, with no reinstatement evidenced. Legacy individually-tagged designations persist on the OFAC Specially Designated Nationals list, but no active country-level program exists.

Cocoa-sector cash intensity remains a standing structural vulnerability. The cash-heavy, export-concentrated cocoa trade is recognised as a structural trade-based money-laundering vulnerability, though no dated enforcement event supports a stronger claim this cycle. This rests on a single weaker source and should be read as a standing typology observation rather than a fresh development.

#### Cross-Monitor Connections

The absence of a UEMOA-wide crypto framework is directly relevant to the world-payments monitor&#x27;s tracking of digital-money infrastructure in the region, and to the crypto monitor&#x27;s tracking of stablecoin and digital-asset regimes across West Africa; both monitors should treat BCEAO&#x27;s C-CRYPTO drafting process as a shared forward-looking anchor. The cocoa-sector trade-based money-laundering vulnerability also connects to commodity-flow-focused monitoring of extractive and agricultural export sectors, where cash-intensive, export-concentrated trade structures recur as a cross-jurisdictional typology.

#### Outlook

The most consequential open question for Cote d&#x27;Ivoire is the timeline and substance of BCEAO&#x27;s eventual UEMOA-wide crypto-asset framework; its absence currently leaves crypto-asset activity touching the country in a regulatory vacuum. On the FATF/GIABA track, the next plenary review will indicate whether the remediation trajectory evidenced by the 3rd Enhanced Follow-Up Report continues to progress toward eventual removal from the increased-monitoring list, or whether momentum stalls.

14 Sep 2026 · fim-2026-09-14

#### Lead Signal

Cote d&#x27;Ivoire&#x27;s AML/CFT trajectory has moved materially toward grey-list exit this cycle. The FATF&#x27;s June 2026 plenary made an initial determination that Cote d&#x27;Ivoire has substantially completed its action plan and now warrants an on-site assessment to verify that implementation has begun and sustained political commitment continues. This is the penultimate procedural step before potential removal from the FATF&#x27;s increased-monitoring list, corroborated by GIABA&#x27;s enhanced follow-up re-ratings, which now place 18 of Cote d&#x27;Ivoire&#x27;s FATF Recommendations at Compliant or Largely Compliant against 22 still rated Partially Compliant.

#### Other Developments

Regulatory perimeter expansion via banking reform. On 29 April 2026 Cote d&#x27;Ivoire&#x27;s Council of Ministers adopted two draft laws modernising the banking and microfinance frameworks to formally recognise FinTech firms, e-money operations and Islamic finance within the regulatory perimeter. This is an AML/CFT-relevant expansion of obliged-entity scope, since formal recognition typically brings previously informal-sector actors within CDD, record-keeping and reporting obligations. The finding rests on a single secondary legal-blog source reporting a Council of Ministers communiqué, with no primary gazette text yet located, capping confidence at Assessed rather than Confirmed.

GIABA follow-up re-ratings. Beyond the headline FATF determination, GIABA&#x27;s most recent follow-up cycle re-rated Cote d&#x27;Ivoire from Partially Compliant to Compliant on Recommendations 11, 18 and 20, and from Partially Compliant to Largely Compliant on Recommendations 10, 12, 16, 19, 22 and 23. This is a structural improvement across the technical-compliance backbone of the regime rather than a single enforcement event, and it is this structural depth that underpins the FATF&#x27;s willingness to consider an on-site verification step.

#### Cross-Monitor Connections

The banking and microfinance draft laws noted above sit at the intersection of AML/CFT obliged-entity scope and payments infrastructure; the World Payments Monitor is separately tracking the same 29 April 2026 Council of Ministers action for its licensing and market-access implications. Readers focused on payment-rail structure rather than financial-crime exposure should consult that monitor&#x27;s treatment of the same underlying instrument.

#### Outlook

The central question for the coming cycle is whether the FATF&#x27;s on-site assessment proceeds and confirms sustained implementation, which would open the door to formal removal from increased monitoring. A secondary thread to watch is whether the banking and microfinance draft laws achieve gazetted, confirmed status, which would resolve the current Assessed-confidence gap and clarify how far Cote d&#x27;Ivoire&#x27;s obliged-entity perimeter is being formally extended to FinTech, e-money and Islamic finance actors.

4 Sep 2026 · fim-2026-08-21

#### Lead Signal

The Financial Action Task Force standing of Côte d&#x27;Ivoire continued to soften this cycle. The FATF December 2025 follow-up report re-rated Côte d&#x27;Ivoire upward on twelve of the forty FATF Recommendations, including a move from partially compliant to largely compliant on Recommendation 1 (High confidence, primary FATF source). This follow-up sustains momentum from the October 2024 high-level political commitment made by Côte d&#x27;Ivoire with FATF and GIABA, though Côte d&#x27;Ivoire remained listed as a jurisdiction under increased monitoring as of the February 2026 plenary statement. The pattern is structural rather than episodic: successive plenary cycles have tracked incremental technical-compliance improvement against a still-open grey-listing, which is the analytically significant read for institutions calibrating country-risk weightings on Côte d&#x27;Ivoire this cycle. This progress is also notable for its breadth: a twelve-Recommendation re-rating in a single follow-up cycle is a wide swath of the FATF forty, and Recommendation 1 specifically concerns a jurisdiction assessment and mitigation of money-laundering and terrorist-financing risk, meaning the upgrade reflects structural progress in the risk-based supervisory architecture of Côte d&#x27;Ivoire rather than a narrow procedural fix.

#### Other Developments

Beneficial-ownership register architecture consolidates. Ordonnance n°2023-875 du 23 novembre 2023 anchors the AML/CFT/CPF legal framework of Côte d&#x27;Ivoire and underpins a beneficial-owners register requiring declaration to the relevant commercial-court registry; nominee shareholders and directors must disclose nominee status within fifteen days of appointment (High confidence, primary judicial-registry source). A separate fiscal-code obligation reinforces the register with fines of XOF 5,000,000 per unmaintained register (Assessed confidence, single legal-commentary source, not independently corroborated against primary fiscal-code text this cycle). Together these instruments describe a legally established beneficial-ownership architecture, though registry uptake and enforcement intensity are not yet independently verified from a supervisory source. The Ordonnance n°2023-875 legal base is drafted as an integrated AML, CFT, and counter-proliferation-financing instrument, though this cycle evidenced developments concentrate on the AML and general technical-compliance dimensions; no distinct CTF- or CPF-specific finding surfaced this cycle for Côte d&#x27;Ivoire, which the three-pillar framing applied here treats as a coverage gap worth naming rather than an implicit finding of CTF/CPF inactivity.

BCEAO signals crypto ML/TF attention without a binding instrument. At a May 2026 international conference on crypto-assets and digital innovation, the BCEAO Governor publicly warned of illicit uses of crypto-assets favourable to money laundering and terrorist financing (Assessed confidence, single press account of a Tier-1 institution public statement). No new binding UEMOA or Côte d&#x27;Ivoire-specific crypto-AML instrument followed this cycle. This places the crypto exposure of Côte d&#x27;Ivoire in a supervisory-attention posture rather than a regulated-obligation one: the institution responsible for eventual rulemaking has publicly named the risk, but has not yet moved to bind obliged entities to a crypto-specific control framework.

#### Cross-Monitor Connections

The beneficial-ownership development sits adjacent to corporate-transparency signal tracked elsewhere in the fleet wherever entities domiciled in Côte d&#x27;Ivoire appear as counterparties. The BCEAO crypto ML/TF warning is the same underlying event referenced by the World Payments Monitor tracking of payment-institution licensing growth in Côte d&#x27;Ivoire and by the Crypto Monitor tracking of the same BCEAO conference; readers following either of those monitors for Côte d&#x27;Ivoire this cycle are seeing the same regional-supervisor statement refracted through a different lens rather than a distinct development. No conflict-finance, extractive-industry, or state-capture connection was identified for Côte d&#x27;Ivoire this cycle.

#### Outlook

The FATF and GIABA continued-monitoring process is expected to produce further plenary reviews through the remainder of 2026, with an estimated impact window in the fourth quarter; continued progress on outstanding action-plan items for Côte d&#x27;Ivoire could support delisting from increased monitoring, while stalled progress would sustain the grey-list status (Assessed confidence). On beneficial ownership, the open question is whether registry uptake and enforcement translate from legal architecture into demonstrated supervisory practice, a gap the current evidence base does not yet close. On crypto, the absence of a binding BCEAO or UEMOA instrument following the public warning from the Governor is itself worth tracking: a shift from rhetorical risk-flagging to a concrete regulatory proposal would be the marker that changes the crypto-AML posture of Côte d&#x27;Ivoire from watch to active. It is also worth naming what did not happen this cycle: no enforcement action, sanction, or penalty was identified against any Côte d&#x27;Ivoire entity in connection with either the beneficial-ownership register or the crypto warning, and under the fleet enablement-as-signal principle that absence is itself a data point about the current stage of both regimes, which sit at legal-architecture and supervisory-attention stages respectively rather than at an enforcement stage.

6 Aug 2026 · fim-2026-08-05

#### Lead Signal

AMLA&#x27;s formal absorption of all anti-money-laundering and counter-terrorist-financing mandates from the European Banking Authority, effective 1 January 2026, and Cote d Ivoire&#x27;s retention on the FATF grey list through the 19 June 2026 plenary together anchor a cycle defined by EU supervisory build-out set against unresolved West African prosecution capacity. AMLA has officially taken over all anti-money laundering and counter-terrorist financing mandates and responsibilities from the European Banking Authority, per AMLA&#x27;s own confirmation, with the AMLR, Regulation (EU) 2024/1624, confirmed to become applicable on 10 July 2027 and direct supervision of forty high-risk cross-border entities beginning in 2028. Read as three distinct instruments, the AMLR (directly applicable), the sixth AML Directive (transposed per Member State), and the AMLA Regulation establishing the Authority itself, this is assessed as the most consequential EU AML supervisory restructuring in over a decade, shifting the supervisory perimeter from purely national authorities toward a hybrid EU level regime.

Set against that architecture, Cote d Ivoire&#x27;s continued grey-list retention reflects, per FATF&#x27;s own June 2026 plenary determination, unresolved money-laundering and terrorist-financing prosecution capacity and sanctions-framework deficiencies rather than a permissive-by-design regime. Cote d Ivoire&#x27;s own jurisdiction-risk signal this cycle is structural rather than episodic: CENTIF-CI reporting and BCEAO mobile-money know-your-customer obligations remain the primary domestic AML architecture, while a single Tier-4 vendor flag on cocoa-export trade-based money laundering could not be corroborated against a primary GIABA source this cycle and is carried here as a low-confidence lead rather than a confirmed vulnerability.

#### Other Developments

The EU&#x27;s 21st Russia sanctions package extends enforcement architecture to sea-based evasion infrastructure. The package introduced 218 designations and marks the first EU designation vector targeting vessels refuelling shadow-fleet tankers at sea, alongside a frozen oil price cap of 44.10 dollars per barrel. This is assessed against an estimated shadow-fleet size that has roughly tripled since 2022, meaning the new designation vector expands enforcement architecture without yet resolving underlying fleet growth.

A FinCEN supplemental alert ties Cartel de Jalisco Nueva Generacion to fuel-theft and smuggling schemes. The direct, Tier-1 FinCEN alert flags suspicious activity connected to the cartel&#x27;s fiscal fuel-theft and smuggling operations, reinforcing Bank Secrecy Act reporting obligations for banks and cross-sector firms handling correspondent-banking and trade-finance flows tied to the scheme.

Colombia received its first failed-demonstrably counternarcotics designation in nearly thirty years. The FY2026 determination finds Colombia to have failed demonstrably to meet international counternarcotics obligations, the first such finding in close to three decades, though the underlying primary determination text was not retrieved this cycle and the claim rests on Tier-3 trade-press reporting.

FATF&#x27;s seventh targeted VASP update characterises Cambodia-based scam centres as significant generators of illicit proceeds. The finding, relayed through a Tier-2 source citing FATF&#x27;s own framing, links industrialised fraud and pig-butchering operations to Recommendation 15 implementation gaps, notwithstanding Cambodia&#x27;s 2023 grey-list exit.

Laos&#x27;s Golden Triangle Special Economic Zone remains, on unchanged low-confidence reporting, under the control of a US-Treasury-sanctioned operator. Zhao Wei is reported to retain control of the zone as an active laundering and scam-centre hub, though this rests on a single Tier-4 non-governmental source with no new primary action located this cycle.

FATF finds that ninety-three percent of jurisdictions have not identified qualifying DeFi arrangements. The same targeted update flags offshore virtual-asset service provider supervisory gaps and stablecoin misuse as increasing risks, a direct, Tier-1 FATF finding.

MiCA&#x27;s stablecoin-issuer authorization deadline has passed, with delisting risk for non-compliant issuers. The 1 July 2026 hard deadline for stablecoin-issuer authorization has now passed; non-compliant issuers face exclusion from EU-regulated trading venues, per Tier-3 reporting on the ESMA-administered regime.

OFAC designated Houthi leadership and financiers in a targeted move against military-procurement capability. The 16 January 2026 action, assessed via Tier-3 legal-advisory reporting cross-referenced against the UN Security Council resolution tracker, targets the financing architecture behind Houthi military procurement.

Cote d Ivoire&#x27;s cocoa-export sector carries an uncorroborated trade-based money-laundering flag. A single Tier-4 vendor source characterises the sector as structurally vulnerable to invoice manipulation and commingling of illicit funds with export revenues; no primary GIABA corroboration was located this cycle, and the claim is carried at low confidence.

#### Cross-Monitor Connections

Cote d Ivoire&#x27;s grey-list status is flagged as relevant to the macro-sanctions monitor on the basis that continued Increased Monitoring status elevates correspondent-bank de-risking pressure on Cote d Ivoire-linked flows. The dark-fleet dimension of the EU&#x27;s 21st sanctions package and the Mexican fuel-smuggling schemes tied to Cartel de Jalisco Nueva Generacion are both flagged as commodity-flow relevant to the extractive and trade-flow monitor. Laos&#x27;s Golden Triangle Special Economic Zone concession dynamics are flagged, at low confidence, to the state-capture monitor as illustrative of state-capacity-ceding institutional-integrity risk. The Houthi financing architecture targeted by OFAC&#x27;s designation is flagged as a FIMI-adjacent covert-financing signal to the information-operations monitor, and the same designation, alongside Colombia&#x27;s narco-finance designation, is flagged to the conflict-finance monitor as directly relevant to armed-group financing tracking. The AMLA and AMLR milestones, together with the MiCA stablecoin deadline, are flagged as core EU-regulatory-gap signals to the EU-regulatory monitor at high confidence.

#### Outlook

The near-term regulatory calendar is dominated by EU AML build-out: AMLA&#x27;s RTS/ITS/GL delivery package is due 10 July 2026, consolidating fragmented national AML technical rules ahead of the AMLR&#x27;s confirmed 10 July 2027 application date, while AMLA&#x27;s broader work programme and supervisory methodology are expected to be published by the end of 2026. Direct AMLA supervision of a first cohort of high-risk cross-border obliged entities begins in 2028, completing the shift toward a hybrid EU-level supervisory perimeter. Assessed against this build-out, the widening divergence between an EU sanctions-enforcement posture that continues to expand shadow-fleet designations and a US posture that has not added new Russia or Iran vessel designations since January 2025 creates differential compliance exposure for correspondent banks operating across both regimes. For Cote d Ivoire specifically, the next material data point is FATF&#x27;s forthcoming plenary movement on the jurisdiction&#x27;s action plan, watched within the coming cycle against a backdrop of continued capacity-constrained, rather than actively permissive, AML posture.

Domain intelligence (D1–D8)

#### Sanctions Architecture and Evasion

Cote d&#x27;Ivoire&#x27;s removal from the FATF list of jurisdictions under increased monitoring, agreed at the 28-30 October 2026 Paris plenary, is best read through a list-architecture lens rather than as a single enforcement milestone. The FATF action concluded a listing that began in October 2024, following a June 2026 determination that the country had substantially completed its action plan. The grey list as a whole fell from 22 to 18 jurisdictions, with Bulgaria, the Democratic Republic of the Congo and Monaco also removed and no new jurisdictions added this round.

Continue reading What makes this a structural rather than incidental development is that the exit coincides with, but does not resolve, a separate and still-active European Union designation. Cote d&#x27;Ivoire remains on the EU&#x27;s list of high-risk third countries, in force since 5 August 2025, which carries its own enhanced due diligence triggers independent of the FATF process. Press commentary has floated the possibility that the European Commission could revisit the designation given the FATF outcome, but no Commission source or review date has been identified. The result is a sanctions-and-list divergence: two list-based regimes assessing the same jurisdiction on related but distinct criteria now point in different directions, with EU obliged entities still required to apply enhanced due diligence to Ivorian exposure regardless of the FATF outcome.

This divergence matters for firms operating across both FATF-aligned and EU-aligned compliance frameworks, since a programme calibrated solely to FATF status would understate ongoing EU-driven due diligence obligations. The two regimes should be tracked and reported on separately rather than collapsed into a single risk rating, given they currently carry materially different and independently dated bases.

#### Outlook

The open question is whether the European Commission moves to reassess Cote d&#x27;Ivoire&#x27;s high-risk third-country status in light of the FATF delisting. Nothing in the current record indicates a confirmed timetable; the only source raising the prospect is press commentary, not an EU primary source. Firms should expect the EU designation to persist on its existing basis for now, with reassessment, if it comes, a matter for a future cycle rather than an imminent change. The FATF side of the picture is more settled: the delisting reflects a multi-year reform programme rather than a provisional correction, and nothing in the current record suggests Cote d&#x27;Ivoire is at near-term risk of re-listing.

Judgment: No CI-specific sanctions-architecture development this cycle. Uncertain

#### Beneficial Ownership and Corporate Transparency

The durable architectural backdrop against which any beneficial-ownership signal for Cote d&#x27;Ivoire should be read is a European one, even though Cote d&#x27;Ivoire sits entirely outside it: the European Union&#x27;s AML Package now rests on three distinct instruments -- a directly-applicable AML Regulation (Regulation (EU) 2024/1624), a sixth AML Directive transposed individually by each member state, and a separate AMLA Regulation (Regulation (EU) 2024/1620) establishing the Anti-Money Laundering Authority. Together these shift beneficial-ownership supervision within the EU from a purely national model toward a hybrid regime with direct and indirect EU-level supervision of the highest-risk obliged entities. Cote d&#x27;Ivoire is not within that perimeter and nothing in this cycle&#x27;s record connects it to AMLA&#x27;s direct-supervision list; the EU architecture is noted here purely as the structural reference point against which a non-EU jurisdiction&#x27;s own progress is measured by outside observers, not as a description of anything applicable to Cote d&#x27;Ivoire itself.

Continue reading Within Cote d&#x27;Ivoire&#x27;s own, directly relevant picture, the material beneficial-ownership signal this cycle comes from the FATF Plenary decision of 28-30 October 2026 removing the country from its increased-monitoring list. FATF&#x27;s own published statement credits the country with improved verification of, and access to, basic and beneficial ownership information as one of the elements supporting closure of its action plan. This is a meaningful signal because beneficial-ownership transparency has historically been one of the harder-to-close items in FATF action plans generally, and its explicit inclusion in the closure statement suggests the underlying registry or verification mechanism had reached a standard FATF&#x27;s evaluators were prepared to credit.

That said, the strength of this specific finding should be read as probable rather than confirmed. No primary Cote d&#x27;Ivoire beneficial-ownership registry instrument, statute, or implementing regulation was independently retrieved this cycle; the entire basis for the improvement claim is FATF&#x27;s own characterisation in its delisting statement, without independent corroboration from a Cote d&#x27;Ivoire-sourced legal instrument. This is an explicitly flagged gap: the research record notes that no BO primary source was located despite the FATF characterisation, and that this is the kind of claim that benefits most from independent confirmation in a subsequent pass. Readers should treat the underlying improvement as credible, given its source, but not yet documented at the instrument level.

The broader implication for corporate transparency practice in Cote d&#x27;Ivoire is that the country has moved from a position where beneficial-ownership deficiencies were serious enough to anchor part of an action plan, to one where FATF&#x27;s evaluators consider those deficiencies substantially remediated. For banks and other obliged entities conducting due diligence on Ivorian corporate counterparties, this translates into a materially improved baseline assumption about the reliability of beneficial-ownership information obtainable in the jurisdiction, though it does not yet amount to a verified description of exactly what registry, database, or verification process now exists.

#### Outlook

The principal item to watch is whether a primary Cote d&#x27;Ivoire beneficial-ownership instrument becomes available for independent review, which would allow the current probable-confidence finding to be upgraded with specificity about the actual legal and operational mechanism FATF credited. Regional follow-up reporting from GIABA, once updated to reflect the October 2026 delisting, is a plausible vehicle for that detail given GIABA&#x27;s role in ongoing supervision of the jurisdiction&#x27;s AML/CFT effectiveness. Until such a primary source surfaces, the beneficial-ownership improvement should be treated as a credible but not yet independently documented element of Cote d&#x27;Ivoire&#x27;s broader AML/CFT reform record.

Judgment: FATF credits improved BO verification/access as part of delisting; no primary CI instrument independently confirmed this cycle. Probable

#### Enabler Jurisdictions and Professional Facilitators

The defining enabler jurisdiction signal for Cote d Ivoire this cycle is a trade based smuggling and laundering architecture built directly on a domestic pricing policy gap. As global cocoa prices roughly tripled since 2023, smuggling networks move Ivorian cocoa beans across porous borders, including into Guinea, via night time motorcycle couriers to bypass the state regulated Conseil du Cafe Cacao pricing system, arbitraging the difference between the domestic fixed price and the world reference price while evading taxation and export controls. Proceeds re enter the formal economy through under and over invoiced cross border trade, a classic trade based money laundering signature layered on top of a commodity specific price control regime. Enforcement seizure activity, referenced as corroborating the scheme, indicates that Ivorian authorities are aware of and actively responding to the pattern, which is analytically important: this is documented as an active enforcement gap rather than an unaddressed one, distinguishing capacity deficit from policy indifference.

Continue reading The structural enabler beneath both the cocoa scheme and the broader smuggling economy is a cash intensive, largely informal economy operating across porous frontiers. The 2023 GIABA Mutual Evaluation found cash confiscations at the border not proportionate to the risks presented by that informal economy, a finding that speaks directly to the enabler jurisdiction analytical question of capacity versus choice. On the evidence reviewed, the disproportion between confiscation activity and underlying risk reads as a resourcing and capability constraint on Ivorian customs and border authorities rather than a deliberate policy of tolerance; the state regulated pricing system that creates the cocoa arbitrage opportunity in the first place is itself evidence of an active, if imperfectly enforced, policy architecture, not a permissive vacuum.

This enabler profile connects directly to the beneficial ownership gap tracked separately in the corporate transparency domain. Nominee arrangements enabled by incomplete beneficial ownership verification capacity provide a plausible mechanism through which trade based laundering proceeds, once re entered into the formal economy via invoicing manipulation, could be further layered through opaque corporate structures facilitated by designated non financial businesses and professions. The interpreter baseline does not evidence a specific documented instance of that layering chain operating end to end this cycle, but the co-location of an active trade based laundering scheme with an unresolved beneficial ownership verification gap constitutes a coherent structural vulnerability rather than two unrelated findings.

Regionally, the same porous border and informal economy characteristics that enable cocoa smuggling into Guinea also structure the southward movement of Sahel linked terrorist financing and the smuggling of artisanal gold through Togo, indicating that the enabler architecture in Cote d Ivoire is not commodity specific but a general function of border capacity and cash economy characteristics that cut across multiple illicit finance typologies simultaneously.

#### Outlook

No enabler jurisdiction specific regulatory or capacity building horizon item was separately identified for Cote d Ivoire this cycle beyond the general trajectory of the FATF action plan and GIABA follow up process already tracked under the sanctions architecture and beneficial ownership domains. The practical marker to watch is whether the November 2026 GIABA Plenary follow up assessment addresses border and cash economy capacity alongside the beneficial ownership verification item specifically, since the Mutual Evaluation finding on disproportionate border cash confiscation has not yet been superseded by any more recent capacity assessment in the sourcing reviewed. Absent a dedicated capacity building programme addressing border cash controls, the structural conditions enabling the cocoa and broader smuggling economy are likely to persist independent of the FATF grey list outcome itself.

Judgment: No CI-specific enabler-jurisdiction development this cycle. Uncertain

#### Conflict Finance and Extractive-Industry Integrity

The defining conflict finance and extractive industry signal for Cote d Ivoire this cycle is an estimated 730.5 million euro annual undeclared gold outflow. Gold from over 240 unlicensed artisanal mining sites is aggregated and smuggled through Abidjan international airport, exploiting weak passenger and freight risk analysis systems at the hub, with the flow co-mingling with organised crime proceeds and, regionally, non state armed group proceeds. This finding is corroborated by a primary source, the UNODC PCBT-AIRCOP programme, giving it a higher evidentiary standing than press only reporting, though no precise event date could be established for the recency window, meaning the estimate should be read as a standing structural characterisation of an ongoing outflow rather than a dated single event.

Continue reading The architecture of this scheme is notable for combining two distinct integrity failures in a single channel: an extractive sector governance failure, in which over 240 unlicensed sites operate outside the formal artisanal mining regulatory perimeter, and an air freight and passenger risk analysis failure at Abidjan international airport, the transit chokepoint through which the aggregated gold exits. Because the smuggling exploits a legitimate international transport hub rather than an informal land border alone, the scheme has a materially different risk surface for financial institutions than the cocoa trade based laundering documented in the enabler jurisdiction domain: trade finance and correspondent banking exposure tied to gold export documentation, rather than agricultural commodity invoicing alone, is the more relevant customer typology.

The regional non state armed group dimension of this co-mingling connects to the broader Sahel spillover terrorist financing pattern tracked separately, in which JNIM and affiliated groups use informal cross border flows to move logistics southward into Cote d Ivoire; the gold outflow finding does not establish a documented direct link between the two schemes, but both point to the same underlying vulnerability of weak border and transit risk analysis capacity being exploited by multiple, distinct illicit actor categories simultaneously.

A further, older data point provides longstanding context rather than a current cycle finding: historical reporting has linked cocoa sector revenue to the Gbagbo era conflict period. This baseline does not substantiate a current cycle conflict cocoa nexus, and it is presented here explicitly as standing historical context for the extractive and agricultural revenue domain rather than as an active finding, consistent with the principle that absence of current substantiation should be stated plainly rather than implied.

#### Outlook

No jurisdiction specific regulatory horizon item addressing gold export controls, air freight risk analysis capacity, or artisanal mining licensing was identified for Cote d Ivoire this cycle beyond the general FATF and GIABA follow up calendar tracked under the sanctions architecture domain. The estimated 730.5 million euro annual outflow figure has not been superseded by any more recent estimate in the sourcing reviewed, and the absence of a precise recency date for the underlying finding means it should be treated as a persisting structural exposure rather than a resolved or time bound one; monitoring the World Customs Organization and UNODC PCBT-AIRCOP programme outputs is the most plausible route to detecting any material change in this specific channel.

Judgment: No CI-specific conflict-finance development this cycle. Uncertain

#### Crypto, Digital Assets, and Financial Innovation

Côte d&#x27;Ivoire&#x27;s directly relevant digital-asset development this period is regulatory rather than enforcement-driven: BCEAO, the regional central bank, opened applications on 14 October 2026 for the first cohort of its Financial Innovation Laboratory sandbox, a programme open to UEMOA fintechs and licensed financial institutions, with applications accepted through 30 November 2026. The sandbox notice explicitly excludes crypto-assets from its testing scope and states that a successful test does not amount to an authorisation of any kind. This is a deliberate perimeter decision, not an oversight: the central bank&#x27;s first formal innovation-testing structure for the currency union has chosen to keep digital assets outside its scope entirely, at a time when the same jurisdiction is also in the final stage of a FATF grey-list exit process. Read together, the two developments suggest a central bank prioritising conventional fintech supervision and AML/CFT credibility ahead of any engagement with crypto-specific regulation. No dedicated crypto-asset law exists anywhere in the UEMOA zone, and BCEAO&#x27;s own C-CRYPTO drafting committee has published no mandate document or timeline locatable this period, leaving the region&#x27;s approach to digital assets effectively unarticulated beyond this sandbox exclusion.

Continue reading

#### Outlook

The enablement-as-signal principle applies directly here: the absence of any crypto-specific enforcement action in Côte d&#x27;Ivoire is not an indication of a permissive regime so much as an indication that no regime exists for regulators to enforce. The sandbox&#x27;s crypto exclusion, set against the backdrop of the pending FATF grey-list verdict, points to a central bank managing its supervisory bandwidth carefully; whether crypto features in any future cohort of the Financial Innovation Laboratory, after the current 30 November 2026 application window closes, will be the first concrete signal of whether that posture is temporary or durable.

Judgment: No CI-specific crypto-AML development this cycle; see crypto consumer section for the unregulated-gap status. Uncertain

#### Compliance Technology and Active Defence

No jurisdiction specific RegTech, AI driven transaction monitoring, or perpetual KYC development was identified for Cote d Ivoire in the baseline evidence reviewed this cycle. The domain tracker status is recorded as watch with a no change trajectory, reflecting an honest absence of CI specific signal rather than an assumption that compliance technology developments are irrelevant to the jurisdiction. The global thesis tracked under this domain, that perpetual KYC and agentic compliance systems are increasingly relevant to how obliged entities manage high risk third country exposure generally, continues under generic cross jurisdiction tracking, but no Cote d Ivoire specific instantiation of that thesis, whether a CENTIF technology initiative, a bank level active defence deployment, or a regional UEMOA supervisory technology programme, appeared in the sourcing reviewed. Given the extent of enhanced due diligence obligations already attached to Cote d Ivoire under both the EU Article 9 and UK Regulation 33 high risk third country mechanisms, the absence of any documented compliance technology response specific to this jurisdiction is itself a modest data point, consistent with a broader observation that administrative listing status does not automatically generate a corresponding compliance technology deployment at the jurisdiction level.

Continue reading

#### Outlook

This entry will be revisited in subsequent cycles as new baseline or update research becomes available; no material change is expected in the near term absent a specific CENTIF or UEMOA level technology initiative, and none was identified in the current gaps register or horizon tracking for this jurisdiction.

Judgment: No CI-specific RegTech/compliance-technology development this cycle. Uncertain

#### AML/CTF Regime

The principal AML/CTF-regime development this cycle is structural: the Financial Action Task Force&#x27;s removal of Cote d&#x27;Ivoire from its list of jurisdictions under increased monitoring, decided at the 28-30 October 2026 Plenary. FATF&#x27;s own publication states plainly that it welcomes the country&#x27;s significant progress in improving its AML/CFT regime, and a companion FATF publication confirms the Plenary&#x27;s agreement to remove Cote d&#x27;Ivoire alongside Bulgaria, the Democratic Republic of the Congo and Monaco from the increased-monitoring list. This is a confirmed-tier finding, resting on FATF&#x27;s own primary publications rather than secondary characterisation, and it should be read as the closure of the action plan the country entered in October 2024.

Continue reading The designation-facts framing that applies here is that removal from the FATF increased-monitoring list ends the elevated-due-diligence treatment that list membership triggers for counterparties applying FATF-aligned frameworks; it is distinct from, and should not be conflated with, any UK, EU or other jurisdiction-specific list mechanism, each of which operates on its own criteria and its own update cadence. The FATF decision alone does not automatically or instantaneously alter every other jurisdiction&#x27;s parallel list; it does, however, remove the predicate FATF-level designation that many of those other mechanisms reference, which is why the development is being treated as structurally significant rather than as a single-list technical change.

The reform record underlying the delisting is described by FATF as spanning institutional, legislative, regulatory and operational improvements, which is consistent with the architecture-over-incident reading this kind of action-plan closure warrants: it reflects sustained capacity-building and reform over a roughly two-year period rather than a single corrective measure taken in response to one deficiency. Cote d&#x27;Ivoire&#x27;s own Ministry of Economy, Finance and Budget is reported, via secondary press coverage, to have welcomed the decision in terms consistent with this framing, describing it as validation of institutional, legislative, regulatory and operational reform undertaken since the action plan began.

The item that most requires monitoring going forward is the state of regional follow-up reporting. The Inter-Governmental Action Group against Money Laundering in West Africa is the FATF-style regional body with ongoing supervisory responsibility for Cote d&#x27;Ivoire&#x27;s AML/CFT effectiveness, and its most recent Follow-Up Report, dated 31 May 2026, predates the October 2026 Plenary decision and has therefore not yet been revised to reflect it. This is a sequencing gap rather than a substantive concern, but it is the most direct next data point that would corroborate, with regional-body-level detail, the FATF Plenary&#x27;s own summary characterisation of the reform.

For institutions applying AML/CTF risk classifications that reference FATF list status, Cote d&#x27;Ivoire&#x27;s removal from increased monitoring is a direct and immediate input: the predicate condition that anchored enhanced due diligence treatment under FATF-aligned frameworks no longer applies. The confirmed-tier nature of this finding, resting as it does on two separate primary FATF publications, gives this cycle&#x27;s AML/CTF signal an unusually solid evidentiary footing compared with typical single-source developments.

#### Outlook

The near-term question is whether GIABA updates its follow-up reporting to formally reflect the delisting, which would provide independent regional-body corroboration of the FATF Plenary&#x27;s reform narrative. Absent a reversal, Cote d&#x27;Ivoire&#x27;s AML/CFT regime should be read as having moved to a materially improved baseline, with the structural reforms underlying the delisting -- rather than any single enforcement action -- being the appropriate frame for understanding the change.

Judgment: FATF&#x27;s removal of Côte d&#x27;Ivoire from its increased-monitoring list is the principal AML/CFT-regime development this cycle, reflecting improved effectiveness against the October 2024 action plan. Probable

#### Commercial Activity

Côte d&#x27;Ivoire&#x27;s fintech and payments sector recorded two notable transactions within the trailing twelve-month D8 observation window. Wave Mobile Money&#x27;s Ivorian subsidiary launched Wave Bank Africa S.A., a licensed commercial bank based in Abidjan, with 20 billion FCFA (approximately 32 million US dollars) in start-up capital. This followed a 117 million euro debt-financing round that closed in June 2025. The conversion of a mobile-money operator into a licensed commercial bank is itself a structural development: it brings Wave&#x27;s Ivorian operations inside the prudential and supervisory perimeter applicable to banks, a materially different regime from the e-money-institution framework it previously operated under. Separately, on 31 December 2025, Côte d&#x27;Ivoire&#x27;s state investment fund, the Caisse des Dépôts et Consignations (CDC-CI), confirmed it had acquired a stake in the Abidjan-based fintech Green Pay, joining existing shareholder Orange Côte d&#x27;Ivoire Participations as an investor. The size of the CDC-CI investment was not disclosed, and reporting on both transactions comes from tier-3 commercial press rather than regulatory filings, so deal mechanics beyond the headline facts should be treated as provisional.

Continue reading From a financial-integrity perspective, commercial consolidation of this kind matters because it changes who is designated an obliged entity, and under what supervisory architecture, within Côte d&#x27;Ivoire&#x27;s financial system. A mobile-money operator converting to a bank licence moves from one AML/CFT supervisory lens to another; a state fund taking an equity stake in a payments fintech brings a sovereign actor into a commercial ownership position inside the payments value chain. Neither transaction has a sanctions, beneficial-ownership-transparency or conflict-finance dimension evidenced in the material available this cycle, and this sub-brief does not reach beyond what the record supports.

#### Outlook

The state&#x27;s continued appetite for fintech investment, evidenced by CDC-CI&#x27;s stake in Green Pay, together with Wave&#x27;s shift into full banking status, points toward continued institutionalisation of Côte d&#x27;Ivoire&#x27;s previously informal mobile-money sector. Should Côte d&#x27;Ivoire exit the FATF list of jurisdictions under increased monitoring at the late-October 2026 Plenary, this consolidation trend would likely accelerate, as reduced enhanced-due-diligence friction from foreign counterparties and investors makes further capital inflows into Ivorian fintech more straightforward to execute and supervise.

Judgment: No CI-specific financial-integrity-sector commercial event this cycle. Uncertain

Regulatory horizon

In Force Pending 2026-Q4 · ±half_year

### FATF/GIABA continued monitoring of CI&#x27;s AML/CFT action plan

Continued FATF plenary reviews may result in delisting from increased monitoring if remaining action-plan items are addressed, or continued listing if progress stalls.

[FATF / GIABA Source](https://www.fatf-gafi.org/en/publications/Mutualevaluations/fur-cote-d-ivoire-2025.html)

In Force Pending 2026-Q4 · ±quarter

### FATF grey-list exit decision for Côte d&#x27;Ivoire

Pending outcome of the 26-30 October 2026 FATF plenary following the September 2026 on-site assessment.

[FATF Source](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html)

2 dated · 4 pending date · baseline financial-integrity-2026-07-05

Role action cards

MLRO

### Cote d&#x27;Ivoire was removed from the FATF increased-monitoring list at the October 2026 Plenary, ending the enhanced-due-diligence predicate that list membership had triggered.

Enhanced due diligence measures applied to Ivorian counterparties on the basis of FATF increased-monitoring status no longer have that predicate condition; risk-rating methodologies referencing FATF list status should be checked for whether they have been updated to reflect the removal. Regional follow-up reporting has not yet caught up with the decision.

3 evidence refs

Compliance

### FATF credits improved beneficial-ownership verification and access as part of Cote d&#x27;Ivoire&#x27;s delisting, though no primary CI instrument was independently confirmed.

Customer due diligence policies referencing Cote d&#x27;Ivoire risk classification should account for the FATF list change; the specific beneficial-ownership improvement should be treated as probable rather than fully documented pending a primary-source instrument.

3 evidence refs

Legal

### No material change for this persona this cycle.

No material change for this persona this cycle

Board

### Cote d&#x27;Ivoire&#x27;s removal from the FATF increased-monitoring list is a structural improvement in the country&#x27;s AML/CFT standing, reflecting a multi-year reform programme.

This reduces the financial-crime risk premium institutions may have been applying to Ivorian exposure and is relevant to broader counterparty and sovereign risk posture discussions at a governance level.

2 evidence refs

CTO

### No material change for this persona this cycle.

No material change for this persona this cycle

Risk

### Cote d&#x27;Ivoire&#x27;s jurisdiction risk direction is assessed as decreasing following the FATF delisting, with cross-monitor relevance to counterparty and sovereign risk exposure.

Risk models incorporating FATF list status as an input factor for Ivorian exposure should reflect the reduced designation; the structural, rather than episodic, nature of the underlying reform supports treating this as a durable shift.

2 evidence refs

Operations

### No material change for this persona this cycle.

No material change for this persona this cycle

Audit

### Regional follow-up reporting on Cote d&#x27;Ivoire&#x27;s AML/CFT effectiveness has not yet been updated to reflect the October 2026 FATF delisting.

Audit trails referencing the jurisdiction&#x27;s FATF status should note the gap between the Plenary decision and the most recent regional follow-up report, dated 31 May 2026, pending an updated report.

1 evidence refs

Scenario sketches

### Illustrative scenario: hybrid EU supervision and jurisdiction-delisting incentives outside the EU AML Package

As the European Union&#x27;s AML Regulation, sixth AML Directive and AMLA Regulation mature into a hybrid supervisory architecture with direct EU-level oversight of certain cross-border obliged entities, a plausible structural dynamic is that non-EEA jurisdictions seeking closer correspondent-banking and investment access to EU-supervised entities face an indirect incentive to align domestic beneficial-ownership and verification standards with the evidentiary bar EU supervisors apply, even without being within the AMLA perimeter themselves. In this illustrative scenario, a jurisdiction recently removed from FATF increased monitoring could use that removal as a platform to pursue closer de facto alignment with EU-style verification standards, independent of any formal EU process, as a route to deepening correspondent relationships. This is an illustrative structural mechanism only, not a description of any confirmed Cote d&#x27;Ivoire policy intention.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)

Tracker Status Note

T1 · Russian Sanctions-Evasion Architecture no_change No CI-specific signal this cycle.

T2 · EU AML Package / AMLA no_change Not applicable; CI is a non-EEA jurisdiction.

T3 · FATF Grey List improving Côte d&#x27;Ivoire removed from FATF increased-monitoring list, 30 October 2026 Plenary.

T4 · Beneficial-Ownership Register Status improving FATF credits CI with improved BO verification/access as part of its action-plan closure.

T5 · Crypto / VASP Regulatory Framework no_change No CI-specific crypto-AML development this cycle; regional BCEAO/UEMOA framework remains unpublished.

T6 · Sanctions Regime Divergence no_change No CI-specific divergence signal this cycle.

Registers

### Enforcement actions

- 1 Feb 2025

- 18 Apr 2025

- 1 May 2025

- 24 Oct 2025

- Operation &#x27;Red Card&#x27; (Nov 2024-Feb 2025) targeted scams involving mobile banking, investment fraud and messaging apps across Benin, Côte d&#x27;Ivoire, Nigeria, Rwanda, South Africa, Togo and Zambia, uncovering over 5,000 victims. 1 Feb 2025

- Security operations initiated at the start of the 2024-25 cocoa harvest targeted smuggling of beans out of Côte d&#x27;Ivoire amid a near-tripling of world cocoa prices since 2023. 18 Apr 2025

- GIABA&#x27;s 2nd Enhanced Follow-Up Report re-rated 12 FATF Recommendations upward following adoption of the AML/CFT/PF Order 2023-875, including targeted financial sanctions provisions (R.6) and customer due diligence requirements. 1 May 2025

- FATF&#x27;s October 2025 progress review recorded steps taken by Côte d&#x27;Ivoire to enhance international cooperation in ML/TF cases, improve BO verification/access and sanctioning, and strengthen targeted financial sanctions implementation. 24 Oct 2025

### Sanctions changes

- 23 Jul 2026

- 16 Jan 2026

- 23 Jan 2026

- The European Commission updated its list of high-risk third countries under Article 9 of the AML Directive, adding Côte d&#x27;Ivoire (alongside Algeria, Angola, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal, Venezuela) following the FATF&#x27;s October 2024 grey-listing; EU obliged entities must now apply enhanced vigilance to CI-linked transactions. 10 Jun 2025

- HM Treasury&#x27;s Money Laundering Advisory Notice lists Côte d&#x27;Ivoire as a High-Risk Third Country under Regulation 33 of the UK MLRs, requiring enhanced customer due diligence and ongoing monitoring by UK regulated firms, confirmed in both the February 2026 and June 2026 updates. 22 Jun 2026

### Regulatory horizon (register)

- FATF/GIABA continued monitoring of CI&#x27;s AML/CFT action plan

- BCEAO/UEMOA crypto-asset regulatory framework (C-CRYPTO drafting)

- AMLD6 beneficial-ownership register transposition (Articles 11-13, 15)

- FATF Plenary decision on CI grey-list delisting

- FATF grey-list exit decision for Côte d&#x27;Ivoire

- Potential EU review of CI high-risk third-country listing

- Potential EU Commission review of Côte d&#x27;Ivoire&#x27;s high-risk third-country listing

- FATF on-site assessment and potential grey-list exit

- GIABA 46th Technical Commission and Plenary review

- EU AML Regulation (AMLR) general application date

- UK HRTC list refresh following next FATF Plenary

### Active schemes

- [HIGH] Cocoa trade based smuggling and laundering

- [HIGH] Illegal artisanal gold mining and air hub smuggling

- [HIGH] Sahel spillover jihadist financing via informal economy

- Digital asset off ramping of mobile banking and investment fraud

- Legal person beneficial ownership verification gap

Sources

- [https://www.fatf-gafi.org/en/countries/detail/C-te-d-Ivoire.html](https://www.fatf-gafi.org/en/countries/detail/C-te-d-Ivoire.html)

- [https://www.anqacompliance.com/cote-divoire-aml-giaba/](https://www.anqacompliance.com/cote-divoire-aml-giaba/)

- [https://www.amla.europa.eu/amla-takes-major-step-toward-harmonised-eu-supervision_en](https://www.amla.europa.eu/amla-takes-major-step-toward-harmonised-eu-supervision_en)

- [https://www.techtimes.com/articles/321441/20260723/eu-passes-218-russia-sanctions-targets-vessels-that-refuel-shadow-fleet-tankers.htm](https://www.techtimes.com/articles/321441/20260723/eu-passes-218-russia-sanctions-targets-vessels-that-refuel-shadow-fleet-tankers.htm)

- [https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern](https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern)

- [https://www.wttlonline.com/stories/colombia-designated-major-trafficker-in-fraa-review,14278](https://www.wttlonline.com/stories/colombia-designated-major-trafficker-in-fraa-review,14278)

- [https://www.chainalysis.com/blog/fatf-7th-targeted-update-crypto-compliance/](https://www.chainalysis.com/blog/fatf-7th-targeted-update-crypto-compliance/)

- [https://wearenotforsale.org/blog/golden-triangle-special-economic-zone-case-study/](https://wearenotforsale.org/blog/golden-triangle-special-economic-zone-case-study/)

- [https://www.fatf-gafi.org/en/publications/Fatfrecommendations/targeted-updated-virtualassets-vasps-2026.html](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/targeted-updated-virtualassets-vasps-2026.html)

- [https://eco.com/support/en/articles/14814632-mica-stablecoin-regulation-2026-update](https://eco.com/support/en/articles/14814632-mica-stablecoin-regulation-2026-update)

- [https://www.steptoe.com/en/news-publications/stepwise-risk-outlook/sanctions-update-january-26-2026.html](https://www.steptoe.com/en/news-publications/stepwise-risk-outlook/sanctions-update-january-26-2026.html)

- [https://www.fatf-gafi.org/fr/countries/detail/C%C3%B4te%20d&#x27;Ivoire.html](https://www.fatf-gafi.org/fr/countries/detail/C%C3%B4te%20d&#x27;Ivoire.html)

- [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2025.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2025.html)

- [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2025.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2025.html)

- [https://www.fatf-gafi.org/en/publications/Mutualevaluations/fur-cote-d-ivoire-2025.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/fur-cote-d-ivoire-2025.html)

- [https://www.knowyourcountry.com/country-reports/cote-divoire/](https://www.knowyourcountry.com/country-reports/cote-divoire/)

- [https://tribunalcommerceabidjan.ci/benef_definition](https://tribunalcommerceabidjan.ci/benef_definition)

- [https://loidici.biz/2024/12/07/chapitre-2-creation-du-registre-des-beneficiaires-effectifs-des-personnes-et-des-constructions-juridiques/lois-article-par-article/plus-de-textes-de-lois/60472/naty/](https://loidici.biz/2024/12/07/chapitre-2-creation-du-registre-des-beneficiaires-effectifs-des-personnes-et-des-constructions-juridiques/lois-article-par-article/plus-de-textes-de-lois/60472/naty/)

- [https://expert-afic.com/lobligation-de-tenue-des-registres-des-titres-nominatifs-et-des-beneficiaires-effectifs-en-cote-divoire/](https://expert-afic.com/lobligation-de-tenue-des-registres-des-titres-nominatifs-et-des-beneficiaires-effectifs-en-cote-divoire/)

- [https://www.aip.ci/361254/cote-divoire-aip-inter-crypto-actifs-la-bceao-alerte-sur-les-risques-de-fraude-et-plaide-pour-une-innovation-financiere-encadree/](https://www.aip.ci/361254/cote-divoire-aip-inter-crypto-actifs-la-bceao-alerte-sur-les-risques-de-fraude-et-plaide-pour-une-innovation-financiere-encadree/)

- [https://www.bceao.int/fr/communique-presse/conference-internationale-2026-de-la-bceao-sur-le-theme-crypto-actifs-et](https://www.bceao.int/fr/communique-presse/conference-internationale-2026-de-la-bceao-sur-le-theme-crypto-actifs-et)

- [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html)

- [https://www.fatf-gafi.org/en/publications/Mutualevaluations/cote-d-ivore-fur-2024.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/cote-d-ivore-fur-2024.html)

- [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html)

- [https://blog.ivoire-juriste.com/2026/05/textes-legislatifs-et-reglementaires-adopts-en-conseil-des-ministres-du-29-04-2026.html](https://blog.ivoire-juriste.com/2026/05/textes-legislatifs-et-reglementaires-adopts-en-conseil-des-ministres-du-29-04-2026.html)

- [https://www.giaba.org/publications/publication_3404.html](https://www.giaba.org/publications/publication_3404.html)

- [https://www.ecofinagency.com/news-finances/2407-57691-waemu-cryptoasset-regulation-remains-in-preparation-bceao-urges-caution](https://www.ecofinagency.com/news-finances/2407-57691-waemu-cryptoasset-regulation-remains-in-preparation-bceao-urges-caution)

- [https://www.federalregister.gov/documents/2017/11/13/2017-24521/removal-of-cte-divoire-sanctions-regulations](https://www.federalregister.gov/documents/2017/11/13/2017-24521/removal-of-cte-divoire-sanctions-regulations)

- [https://www.giaba.org/publications/publication_3312.html](https://www.giaba.org/publications/publication_3312.html)

- [https://www.moodys.com/web/en/us/kyc/resources/insights/understanding-the-6th-anti-money-laundering-directive-6amld-key-changes-and-compliance.html](https://www.moodys.com/web/en/us/kyc/resources/insights/understanding-the-6th-anti-money-laundering-directive-6amld-key-changes-and-compliance.html)

- [https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/](https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/)

- [https://www.financialafrik.com/2026/08/26/lencadrement-des-cryptoactifs-dans-luemoa-entre-innovation-financiere-et-preservation-de-la-stabilite-monetaire/](https://www.financialafrik.com/2026/08/26/lencadrement-des-cryptoactifs-dans-luemoa-entre-innovation-financiere-et-preservation-de-la-stabilite-monetaire/)

- [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html)

- [Tresor Public CI](https://tresor.gouv.ci/tres/lutte-contre-le-blanchiment-de-capitaux-la-cote-divoire-a-loeuvre-pour-sortir-de-la-liste-grise-du-gafi/)

- [Afrique Sur 7](https://www.afrique-sur7.fr/blanchiment-de-capitaux-la-cote-divoire-attend-le-verdict-du-gafi)

- [BCEAO](https://www.bceao.int/fr/communique-presse/transactions-de-monnaie-electronique-entre-personnes-physiques-par-lintermediaire)

- [CENTIF-CI](https://www.centif.ci/images/publications/fichiers/rem2023.pdf)

- [KnowYourCountry](https://www.knowyourcountry.com/country-reports/cote-divoire/)

- [https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Cote-d-Ivoire-rapport-suivi-mai-2025.pdf.coredownload.inline.pdf](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Cote-d-Ivoire-rapport-suivi-mai-2025.pdf.coredownload.inline.pdf)

- [https://www.giaba.org/mutualevaluation/index.html](https://www.giaba.org/mutualevaluation/index.html)

- [https://www.fatf-gafi.org/en/countries/global-network/inter-governmental-action-group-against-money-laundering-in-west.html](https://www.fatf-gafi.org/en/countries/global-network/inter-governmental-action-group-against-money-laundering-in-west.html)

- [https://www.state.gov/reports/2026-investment-climate-statements/cote-divoire](https://www.state.gov/reports/2026-investment-climate-statements/cote-divoire)

- [https://www.ecofinagency.com/news-finances/2610-49842-wave-launches-commercial-bank-in-cote-d-ivoire](https://www.ecofinagency.com/news-finances/2610-49842-wave-launches-commercial-bank-in-cote-d-ivoire)

- [https://launchbaseafrica.com/2026/01/07/ivory-coasts-state-backed-fund-doubles-down-on-fintech-with-new-green-pay-investment/](https://launchbaseafrica.com/2026/01/07/ivory-coasts-state-backed-fund-doubles-down-on-fintech-with-new-green-pay-investment/)

- [Droit Médias Finance](https://www.droitmediasfinance.com/index.php/actualites/droit-ohada-affaires/681-cote-divoire-une-ordonnance-vient-preciser-les-regles-anti-blanchiment-des-capitaux-incluant-les-cryptoactifs)

- [https://beninwebtv.com/bceao-fintechs-laboratoire-candidatures-30-novembre-2026/](https://beninwebtv.com/bceao-fintechs-laboratoire-candidatures-30-novembre-2026/)

- [https://fr.apanews.net/security/rci-justice-plus-de-1000-dossiers-de-blanchiment-ouverts/](https://fr.apanews.net/security/rci-justice-plus-de-1000-dossiers-de-blanchiment-ouverts/)

- [FATF/GAFI](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2026.html)

- [FATF/GAFI](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-october-2026.html)

- [FATF/GAFI](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html)

- [U.S. Treasury FinCEN](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-6)

- [allAfrica](https://fr.allafrica.com/stories/202610310033.html)

- [Fraternité Matin](https://www.fratmat.info/article/2645560/economie/ocde/blanchiment-de-capitaux-et-financement-du-terrorisme-la-cote-divoire-sort-de-la-liste-grise-du-gafi)

- [CENTIF-CI / Journal Officiel](https://www.centif.ci/wp-content/uploads/2025/03/ORDONNANCE-N2023-875-DU-23-NOVEMBRE-2023-RELATIVE-A-LA-LUTTE-CONTRE-LES-BLANCHIMENTS-DE-CAPIT.pdf)

- [BCEAO](https://www.bceao.int/fr/appel-candidatures-relatif-la-premiere-cohorte-du-laboratoire-dinnovation)

- [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2026.html)

- [https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-october-2026.html](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-october-2026.html)

- [https://africafintechnetwork.com/cote-divoire-exit-fatf-money-laundering-list/](https://africafintechnetwork.com/cote-divoire-exit-fatf-money-laundering-list/)

- [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html)

- ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html)

- [Côte d&#x27;Ivoire](https://www.fatf-gafi.org/en/countries/detail/C-te-d-Ivoire.html)

- [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html)

- [Jurisdictions under Increased Monitoring - 25 October 2024](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2024.html)

- [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html)

- [FATF changes its grey listing criteria to further focus on risk](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-grey-listing-criteria.html)

- [Countries / Jurisdictions](https://www.fatf-gafi.org/en/countries.html)

- [What we do](https://www.fatf-gafi.org/en/the-fatf/what-we-do.html)

- [High-Risk Jurisdictions subject to a Call for Action - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-february-2026.html)

- [Côte d&#x27;Ivoire&#x27;s progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/fur-cote-d-ivoire-2025.html)

- [1st Enhanced Follow-Up Report - Côte d&#x27;Ivoire 2024](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/GIABA-Cote-d-Ivoire-1st-Follow-Up-Report.pdf.coredownload.inline.pdf)

- [Côte d&#x27;Ivoire&#x27;s measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/mer-cote-d-ivoire-2023.html)

- [Jurisdictions under Increased Monitoring - 24 October 2025](https://www.fatf-gafi.org/content/fatf-gafi/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html)

- [Democratic Republic of Congo](https://www.fatf-gafi.org/en/countries/detail/Democratic-Republic-of-Congo.html)

- [Jurisdictions under Increased Monitoring - 13 June 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2025.html)

- [Jurisdictions under Increased Monitoring - 21 February 2025](https://www.fatf-gafi.org/content/fatf-gafi/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2025.html)

- [Senegal](https://www.fatf-gafi.org/en/countries/detail/Senegal.html)

- [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en)

- [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-1)

- [Côte d’Ivoire: is cocoa money propping up Gbagbo regime? | Global Witness](https://www.globalwitness.org/en/archive/cte-divoire-cocoa-money-propping-gbagbo-regime/)

- [Hot chocolate: How cocoa fuelled the conflict in Côte d’Ivoire | Global Witness](https://globalwitness.org/en/campaigns/conflict-resources/hot-chocolate-how-cocoa-fuelled-the-conflict-in-cote-divoire/)

- [Overseas business risk: Cote d&#x27;Ivoire - GOV.UK](https://www.gov.uk/government/publications/overseas-business-risk-cote-divoire/overseas-business-risk-cote-divoire)

- [Ivory Coast Seizes 594 Tons of Smuggled Cocoa Beans - Bloomberg](https://www.bloomberg.com/news/articles/2025-04-18/ivory-coast-seizes-594-tons-of-cocoa-in-clampdown-on-smuggling)

- [Watch Why Are People Smuggling Cocoa Beans out of Ivory Coast? - Bloomberg](https://www.bloomberg.com/news/videos/2025-06-17/why-are-people-smuggling-cocoa-beans-out-of-ivory-coast-video)

- [Ivory Coast: High Cocoa Prices Drive Smuggling Surge - Bloomberg](https://www.bloomberg.com/news/articles/2025-06-17/ivory-coast-high-cocoa-prices-drive-smuggling-surge)

- [How Semlex and Gunvor Armed the Ivorian Civil War | OCCRP](https://www.occrp.org/en/project/biometric-bribery-inside-semlexs-global-playbook/how-semlex-and-gunvor-armed-the-ivorian-civil-war)

- [Satellite-based high-resolution maps of cocoa planted area for C\^ote d&#x27;Ivoire and Ghana](https://arxiv.org/pdf/2206.06119)

- [Identifying the community structure of the international food-trade multi network](https://arxiv.org/pdf/1711.05784)

- [Money Laundering Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2)

- [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2)

- [ECSH31555 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh31555)

- [Enhanced due diligence: designation of high-risk countries](https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1165484/Updated_Impact_Assessment_-_HRTC_Measure_amendement_2_ECCTB_21.06.23_MIN_CLEARED.pdf)

- [ECSH64830 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh64830)

- [HM Treasury Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/hm-treasury-advisory-notice-high-risk-third-countries)

- [Page 1 of 5 HM Treasury Advisory Notice: Changes to the FATF’s Public Lists](https://assets.publishing.service.gov.uk/media/69988878b33a4db7ff889ef3/Annex_C_-_Advisory_Notice_-_February_2026.pdf)

- [High-risk third countries](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/high-risk-third-countries)

- [ECSH33336 - High-risk third countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh33336)

- [2025 UNODC and European Union Launch Regional Program to Strengthen Criminal Justice Responses to Terrorism in West Africa’s Coastal States](https://www.unodc.org/unodc/en/terrorism/latest-news/2025-unodc-and-european-union-launch-regional-program-to-strengthen-criminal-justice-responses-to-terrorism-in-west-africas-coastal-states.html)

- [Sahel Now Accounts for Half of Global Terror Deaths, Secretary-General Tells Security Council, Urging Coordinated Action | UN Meetings Coverage and Press Releases](https://press.un.org/en/2025/sc16226.doc.htm)

- [Security Council Told Political Upheaval, Violent Extremism Continue to Challenge West Africa, Sahel Region | UN Meetings Coverage and Press Releases](https://press.un.org/en/2025/sc16257.doc.htm)

- [1 EU contribution to the report of the Secretary-General to the eightieth](https://www.un.org/en/ga/sixth/80/int_terrorism/eu_e.pdf)

- [UN envoy urges international support for West Africa and the Sahel | UN News](https://news.un.org/en/story/2025/04/1161846)

- [Amid Increased Terrorist Activity in Sahel Region, Speakers Tell Security Council Greater Commitment Needed for Joint Force | UN Meetings Coverage and Press Releases](https://press.un.org/en/2019/sc14027.doc.htm)

- [Terrorist Financing in West Africa](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Tf-west-africa.html)

- [‘African-led, African-owned Solutions Must Take Lead in Tackling Terrorism across Continent’, Deputy Secretary-General Tells Security Council Debate | UN Meetings Coverage and Press Releases](https://press.un.org/en/2025/dsgsm1957.doc.htm)

- [Cote d&#x27;Ivoire statement -- International Terrorism](https://www.un.org/en/ga/sixth/77/pdfs/statements/int_terrorism/04mtg_cotedivoire.pdf)

- [UNODC through PCBT-AIRCOP Strengthens the Regional Fight against Gold Trafficking in West and Central Africa](https://www.unodc.org/unodc/en/organized-crime/AIRCOP/News/unodc-through-pcbt-aircop-strengthens-the-regional-fight-against-gold-trafficking-in-west-and-central-africa.html)

- [Africa Gold Advisory](https://ofac.treasury.gov/system/files/2023-06/africa_gold_advisory_06272023.pdf)

- [Part 2b – Minerals Crime: Illegal Gold Mining](https://www.unodc.org/documents/data-and-analysis/Crimes%20on%20Environment/ECR25_P2b_Minerals_Crime.pdf)

- [GOLD TRAFFICKING IN THE SAHEL](https://www.unodc.org/documents/data-and-analysis/tocta_sahel/TOCTA_Sahel_Gold_v5.pdf)

- [FATF REPORT Money laundering / terrorist financing risks and vulnerabilities](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/ML-TF-risks-vulnerabilities-associated-with-gold.pdf)

- [EU supports first traceable artisanal gold supply chain in Côte d’Ivoire](https://fpi.ec.europa.eu/news/eu-supports-first-traceable-artisanal-gold-supply-chain-cote-divoire-2020-11-26_en)

- [Comprehensive Update on Terrorist Financing Risks FATF REPORT July 2025](https://www.fatf-gafi.org/content/dam/fatf-gafi/publications/Comprehensive-Update-on-Terrorist-Financing-Risks-2025.pdf.coredownload.inline.pdf)

- [Report: Criminals in Central Africa Profit from New Surge in Gold Prices | OCCRP](https://www.occrp.org/en/daily/14747-report-criminals-in-central-africa-profit-from-new-surge-in-gold-prices)

- [RESPONDING TO ILLEGAL MINING AND TRAFFICKING IN METALS AND MINERALS](https://www.unodc.org/cld/uploads/pdf/Illegal_Mining_and_Trafficking_in_Metals_and_Minerals_E.pdf)

- [1 BY OPIATE TRAFFICKERS AND MIGRANT SMUGGLERS The Hawala System](https://www.unodc.org/documents/data-and-analysis/AOTP/Hawala_Digital.pdf)

- [Cote-d-Ivoire-rapport-suivi-mai-2025. ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Cote-d-Ivoire-rapport-suivi-mai-2025.pdf.coredownload.inline.pdf)

- [Côte d&#x27;Ivoire](https://www.fatf-gafi.org/fr/countries/detail/C%C3%B4te%20d&#x27;Ivoire.html)

- [GIABA-French-Cote-d-Ivoire-1st-FUR. ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/translations/FSRB-FUR/GIABA-French-Cote-d-Ivoire-1st-FUR.pdf.coredownload.inline.pdf)

- [Nations Unies CAC/COSP/IRG/2025/CRP.14 Conférence des États Parties à](https://track.unodc.org/uploads/documents/UNCAC/WorkingGroups/ImplementationReviewGroup/18-December-2025/CAC-COSP-2025-IRG-CRP.14.pdf)

- [Un système efficace de lutte contre le blanchiment d&#x27;argent et le financement du terrorisme](https://www.fatf-gafi.org/fr/publications/Gafiengeneral/Efficacite.html)

- [La liste noire et la liste grise - FATF](https://www.fatf-gafi.org/fr/countries/liste-noire-et-liste-gris.html)

- [Juridictions soumises à une surveillance renforcée - 13 février 2026](https://www.fatf-gafi.org/fr/publications/Juridictions-haut-risques-et-sous-surveillance/surveillance-renforcee-fevrier-2026.html)

- [NORMES INTERNATIONALES SUR LA LUTTE CONTRE LE BLANCHIMENT DE](https://www.fatf-gafi.org/content/dam/fatf-gafi/recommendations/Recommandations%20du%20GAFI%202012.pdf.coredownload.pdf)

- [Récents développements du GIABA et GAFI et future coopération renforcée](https://www.fatf-gafi.org/fr/publications/Gafiengeneral/Recentsdeveloppementsdugiabaetgafietfuturecooperationrenforcee.html)

- [Les Recommandations du GAFI - FATF](https://www.fatf-gafi.org/fr/publications/Recommandationsgafi/Recommandations-gafi.html)

- [Guidance on Beneficial Ownership and Transparency of Legal Arrangements](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.html)

- [Guidance on Beneficial Ownership of Legal Persons](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html)

- [Beneficial Ownership](https://www.fatf-gafi.org/en/topics/beneficial-ownership.html)

- [Nigeria-FUR-GIABA-November-2024. ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Nigeria-FUR-GIABA-November-2024.pdf)

- [Treasury Department won’t enforce beneficial ownership rule under the Corporate Transparency Act - ICIJ](https://www.icij.org/inside-icij/2025/03/treasury-department-wont-enforce-beneficial-ownership-rule-under-the-corporate-transparency-act/)

- [Interim Final Rule: Questions and Answers | FinCEN.gov](https://www.fincen.gov/boi/ifr-qa)

- [Best Practices on Beneficial Ownership for Legal Persons](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Best-practices-beneficial-ownership-legal-persons.html)

- [IP Country Fiche - Cote D´Ivoire - Intellectual Property Helpdesk](https://intellectual-property-helpdesk.ec.europa.eu/system/files/2022-08/COTE-DIVOIRE_IP-Country-Fiche.pdf)

- [Register an overseas entity and its beneficial owners - GOV.UK](https://www.gov.uk/guidance/register-an-overseas-entity)

- [African Authorities Bust Cybercrime Networks | OCCRP](https://www.occrp.org/en/news/african-authorities-bust-cybercrime-networks)

- [2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2026-crypto-crime-report)

- [1st West Africa Cybercrime Summit](https://www.unodc.org/conig/en/stories/1st-west-africa-cybercrime-summit.html)

- [What to know about cybercrime in 2026](https://www.unodc.org/unodc/frontpage/2025/October/what-to-know-about-cybercrime-in-2025.html)

- [2026 Crypto Crime Report Introduction - Chainalysis](https://www.chainalysis.com/blog/2026-crypto-crime-report-introduction/)

- [Cybercrime Crackdown Nets 18 Suspects, 300M Euros in Credit Card Fraud | OCCRP](https://www.occrp.org/en/news/cybercrime-crackdown-nets-18-suspects-300m-euros-in-credit-card-fraud)

- [2026 Crypto Crime Report: Scams](https://www.chainalysis.com/blog/crypto-scams-2026/)

- [The ubiquitous crime: fraud, explained](https://www.unodc.org/unodc/frontpage/2026/March/the-ubiquitous-crime_-fraud--explained.html)

- [Stories from UNODC](https://www.unodc.org/unodc/en/frontpage/index.html)

- [Inflection Point: Global Implications of Scam Centres, Underground Banking and](https://www.unodc.org/roseap/uploads/documents/Publications/2025/Inflection_Point_2025.pdf)

- [Côte d&#x27;Ivoire Sanctions Regulations Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20110106)

- [Issuance of Executive Order Terminating Côte d’Ivoire-related Sanctions Program; Côte d’Ivoire-related Designations Removals | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20160914)

- [Ukraine-related Designations; Sectoral Sanctions Identifications; Cote d&#x27;Ivoire Designation Removals; Issuance of an Important Crimea Sanctions Advisory | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20150730)

- [OFAC REGULATIONS FOR THE FINANCIAL COMMUNITY](https://ofac.treasury.gov/media/16151/download)

- [Executive Order 13382, "Blocking Property of Weapons of Mass Destruction](https://ofac.treasury.gov/media/8581/download?inline=)

- [Sanctions | Conseil de sécurité](https://main.un.org/securitycouncil/en/sanctions/information)

- [Sanctions and Other Committees | Security Council](https://main.un.org/securitycouncil/en/content/repertoire/sanctions-and-other-committees)

- [[Type text] Page 1 SOUTH SUDAN SANCTIONS PROGRAM](https://ofac.treasury.gov/system/files/126/overview-of-sanctions-southsudan.pdf)

- [The Côte d’Ivoire (Sanctions) (Overseas Territories) Order 2012](https://www.legislation.gov.uk/uksi/2012/3067/made/data.html)

- [La Reine Máxima en visite en Côte d&#x27;Ivoire et au Sénégal pour promouvoir l&#x27;inclusion financière et numérique | Les Nations Unies en Côte d&#x27;Ivoire](https://cotedivoire.un.org/fr/185539-la-reine-m%C3%A1xima-en-visite-en-c%C3%B4te-divoire-et-au-s%C3%A9n%C3%A9gal-pour-promouvoir-linclusion)

- [La Reine Máxima en visite en Côte d&#x27;Ivoire et au Sénégal pour promouvoir l&#x27;inclusion financière et numérique . | Les Nations Unies au Sénégal](https://senegal.un.org/fr/186001-la-reine-m%C3%A1xima-en-visite-en-c%C3%B4te-divoire-et-au-s%C3%A9n%C3%A9gal-pour-promouvoir-linclusion)

- [L’UNSGSA, la reine Máxima, entend promouvoir l’inclusion financière numérique lors d’une visite virtuelle de la Côte d’Ivoire | Les Nations Unies en Côte d&#x27;Ivoire](https://cotedivoire.un.org/fr/131820-l%E2%80%99unsgsa-la-reine-m%C3%A1xima-entend-promouvoir-l%E2%80%99inclusion-financi%C3%A8re-num%C3%A9rique-lors-d%E2%80%99une)

- [Crypto-assets - Finance - European Commission](https://finance.ec.europa.eu/digital-finance/crypto-assets_en)

- [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/)

- [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26)

- [AFRICA MULTI-STAKEHOLDER CONSULTATION ON](https://www.un.org/esa/ffd/wp-content/uploads/2014/10/se-msc2005-Summary-Bamako.pdf)

- [Inter Governmental Action Group against Money Laundering in West Africa (GIABA)](https://www.fatf-gafi.org/en/countries/global-network/inter-governmental-action-group-against-money-laundering-in-west.html)

- [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html)

- [Côte d&#x27;Ivoire&#x27;s progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/cote-d-ivore-fur-2024.html)

- [GIABA Mutual Evaluation Report - Côte d&#x27;Ivoire - 2023](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/Cote-d-Ivoire-MER-Giaba-2023.pdf.coredownload.inline.pdf)

- [FATF](https://www.fatf-gafi.org/en/home.html)

- [Events](https://www.fatf-gafi.org/en/calendars/events.html)

- [Financial Action Task Force (FATF)](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html)

- [GIABA (Inter-Governmental Action Group against Money Laundering in West Africa)](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/Cote-d-Ivoire-MER-Giaba-2023.pdf.coredownload.inline.pdf)

- [GIABA](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Cote-d-Ivoire-rapport-suivi-mai-2025.pdf.coredownload.inline.pdf)

- [European Commission](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en)

- [HM Treasury](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2)

- [OCCRP](https://www.occrp.org/en/news/african-authorities-bust-cybercrime-networks)

- [Bloomberg](https://www.bloomberg.com/news/articles/2025-06-17/ivory-coast-high-cocoa-prices-drive-smuggling-surge)

- [UNODC](https://www.unodc.org/unodc/en/organized-crime/AIRCOP/News/unodc-through-pcbt-aircop-strengthens-the-regional-fight-against-gold-trafficking-in-west-and-central-africa.html)

- [Global Witness](https://www.globalwitness.org/en/archive/cte-divoire-cocoa-money-propping-gbagbo-regime/)

- [UNODC / UNCAC Implementation Review Group](https://track.unodc.org/uploads/documents/UNCAC/WorkingGroups/ImplementationReviewGroup/18-December-2025/CAC-COSP-2025-IRG-CRP.14.pdf)

- [TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2026-crypto-crime-report)

- [Chainalysis](https://www.chainalysis.com/blog/2026-crypto-crime-report-introduction/)

Coverage gaps

fim-int-2026-07-07-G001: No Cote d Ivoire specific VASP regi… fim-int-2026-07-07-G001: No Cote d Ivoire specific VASP registration data, national crypto asset regulatory framework, or dedicated CENTIF crypto typology report is available to corroborate D5 tracker findings beyond Interpol enforcement reporting. [resolved]

fim-int-2026-07-07-G002: Independent, itemised terrorist fin… fim-int-2026-07-07-G002: Independent, itemised terrorist financing prosecution and conviction statistics beyond the FATF and GIABA summary statements are absent, limiting verification of the near zero conviction claim. [resolved]

fim-int-2026-07-07-G003: The outcome of the FATF on site ass… fim-int-2026-07-07-G003: The outcome of the FATF on site assessment following the June 2026 substantial completion determination is not yet published, leaving the grey list exit timeline and beneficial ownership implementation depth unverified. [resolved]

fim-int-2026-07-07-G004: Regional UEMOA and BCEAO wide AML/C… fim-int-2026-07-07-G004: Regional UEMOA and BCEAO wide AML/CFT and crypto policy harmonisation documentation is sparse relative to national level FATF and GIABA reporting, limiting assessment of cross border enabler dynamics with Guinea, Togo, Benin and Nigeria. [resolved]

fim-int-2026-08-05-G001: No CI-specific beneficial-ownership… fim-int-2026-08-05-G001: No CI-specific beneficial-ownership registry effectiveness data located this cycle. [resolved]

fim-int-2026-08-05-G002: No material RegTech/AI-compliance g… fim-int-2026-08-05-G002: No material RegTech/AI-compliance guidance development identified for Côte d&#x27;Ivoire or globally this cycle beyond FATF VASP framing. [resolved]

fim-int-2026-08-05-G003: No primary GIABA corroboration loca… fim-int-2026-08-05-G003: No primary GIABA corroboration located for the cocoa-sector TBML vulnerability claim. [resolved]

fim-int-2026-08-05-G004: No primary EU Council designation-l… fim-int-2026-08-05-G004: No primary EU Council designation-list text retrieved for the 21st sanctions package. [resolved]

fim-int-2026-08-21-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-08-21-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D3&#x27;}): No CI-specific enabler-jurisdiction (D3) material was located this cycle despite the jurisdiction&#x27;s regional trade-corridor exposure. [resolved]

fim-int-2026-08-21-G002: Tier D jurisdiction checks (KH, LA,… fim-int-2026-08-21-G002: Tier D jurisdiction checks (KH, LA, MX, CO) were not reached this cycle; the pooled union research budget prioritised CI-scoped queries. [resolved]

fim-int-2026-08-21-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-08-21-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D2&#x27;}): BO register enforcement intensity and registry uptake are not yet independently verified from a T1 supervisory source. [resolved]

fim-int-2026-09-14-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-14-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D2&#x27;}): No D2 beneficial-ownership finding located for CI this cycle. [resolved]

fim-int-2026-09-14-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-14-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D3&#x27;}): No D3 enabler-jurisdiction finding located for CI this cycle. [resolved]

fim-int-2026-09-14-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-14-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D7&#x27;}): No T1 gazette text confirming enactment of the 29 April 2026 banking/FinTech draft laws was located; confidence capped at Assessed pending T1 confirmation. [resolved]

fim-int-2026-09-22-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-22-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D2&#x27;}): No CI-specific T1 beneficial-ownership register source was reached this cycle; D2 coverage remains thin. [resolved]

fim-int-2026-09-22-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-22-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D3&#x27;}): No CI-specific enabler-jurisdiction/professional-facilitator source was reached this cycle; D3 coverage remains thin. [resolved]

fim-int-2026-09-22-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-22-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D7&#x27;}): No T1 anchor for CENTIF-CI&#x27;s FIU designation was retrieved this cycle; only a single T3 source supports the current architecture description. [resolved]

fim-int-2026-09-22-G004: Tier-D watch jurisdictions (KH/LA/M… fim-int-2026-09-22-G004: Tier-D watch jurisdictions (KH/LA/MX/CO) were not actively searched this cycle; the pooled search budget was concentrated on the bound JID (CI) per union JID-binding rule. [resolved]

fim-int-2026-09-28-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-28-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D7&#x27;}): GIABA&#x27;s 3rd Enhanced Follow-Up Report and second-round mutual evaluation first report for CI (2026) were surfaced only as a publication listing; substantive report content was not retrieved this cycle. [resolved]

fim-int-2026-09-28-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-28-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D3&#x27;}): No CI-specific enabler-jurisdiction (D3) or conflict-finance (D4) finding was substantiated this cycle within the pooled search budget available. [resolved]

fim-int-2026-09-28-G003: Tier D jurisdictions Laos, Mexico a… fim-int-2026-09-28-G003: Tier D jurisdictions Laos, Mexico and Colombia were not actively searched this cycle due to pooled union search-budget constraints; recorded as awaiting_primary_source, not asserted no-activity. [resolved]

fim-int-2026-10-04-G001: D2/D3/D4/D6 coverage for CI is thin… fim-int-2026-10-04-G001: D2/D3/D4/D6 coverage for CI is thin this cycle; no specific beneficial-ownership, enabler-jurisdiction, conflict-finance or RegTech development was located. [resolved]

fim-int-2026-10-04-G002: Tier D watch jurisdictions (KH, LA,… fim-int-2026-10-04-G002: Tier D watch jurisdictions (KH, LA, MX, CO) were not actively searched this run per the pooled union search-budget allocation to CI. [resolved]

fim-int-2026-10-04-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-04-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D5&#x27;}): No current BCEAO/CREPMF PSAV sanctions-penalty schedule text was located, limiting confidence on enforcement consequences of unlicensed VASP activity. [resolved]

fim-int-2026-10-11-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-11-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D1&#x27;}): No Côte d&#x27;Ivoire-specific sanctions, conflict-finance or compliance-technology development was located this cycle; D1, D3 (beyond the DNFBP designation), D4, D5 (beyond the BCEAO caution), and D6 remain thinly covered for this jurisdiction. [resolved]

fim-int-2026-10-11-G002: FIM&#x27;s standing Tier-D (KH/LA/MX/CO)… fim-int-2026-10-11-G002: FIM&#x27;s standing Tier-D (KH/LA/MX/CO) multi-jurisdiction sweep was not run this cycle because the pooled search budget was directed entirely at Côte d&#x27;Ivoire under the single-JID dispatch protocol. [resolved]

fim-int-2026-10-18-G001: Tier D jurisdictions (Cambodia, Lao… fim-int-2026-10-18-G001: Tier D jurisdictions (Cambodia, Laos, Mexico, Colombia) were not actively searched this cycle; pooled web-search budget was allocated to Côte d&#x27;Ivoire across five consumers. [resolved]

fim-int-2026-10-18-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-18-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D3&#x27;}): D3 (enabler jurisdictions) and D4 (conflict finance) returned no CI-specific material this cycle. [resolved]

fim-int-2026-10-18-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-18-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D5&#x27;}): BCEAO Instruction n°020 and Avis N°0019 full primary-text PDFs were not directly retrieved this cycle, only secondary reporting plus a BCEAO index page confirming existence. [resolved]

fim-int-2026-11-01-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-11-01-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D7&#x27;}): ARJH&#x27;s own regulator domain and LONACI&#x27;s concession-performance disclosures were not directly retrieved this pass; CI T1 Tier-D watch jurisdictions (KH, LA, MX, CO) were not re-swept this cycle as pooled research budget was scoped to CI. [open]

fim-int-2026-11-01-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-11-01-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D7&#x27;}): No EU Commission primary page was retrieved confirming the EU high-risk third-country list&#x27;s current content or any review timetable for Côte d&#x27;Ivoire post-FATF-delisting. [open]

fim-int-2026-11-08-G001: No D2 beneficial-ownership registry… fim-int-2026-11-08-G001: No D2 beneficial-ownership registry primary instrument was independently retrieved for Côte d&#x27;Ivoire this cycle despite FATF&#x27;s characterisation of improvement. [open]

fim-int-2026-11-08-G002: No D3/D4/D5/D6/D8 CI-specific findi… fim-int-2026-11-08-G002: No D3/D4/D5/D6/D8 CI-specific findings were located this cycle; coverage is thin across enabler-jurisdiction, conflict-finance, crypto, compliance-technology and commercial-activity domains. [open]

fim-int-2026-11-08-G003: GIABA&#x27;s own Follow-Up Report has no… fim-int-2026-11-08-G003: GIABA&#x27;s own Follow-Up Report has not yet been updated to reflect the October 2026 FATF delisting; next cycle should check for an updated GIABA report. [open]

FIM-GAP-001 (D1): The 2023 GIABA Mutual Evaluation found Côt… FIM-GAP-001 (D1): The 2023 GIABA Mutual Evaluation found Côte d&#x27;Ivoire had initiated nine TF prosecutions with none reaching trial and no convictions or confiscations obtained; FATF&#x27;s 2026 statements continue to call for a sustained increase in ML/TF prosecutions in line with the country&#x27;s risk profile.

FIM-GAP-002 (D2): Verification and access to beneficial and … FIM-GAP-002 (D2): Verification and access to beneficial and basic ownership information of legal persons, and application of sanctions for BO-obligation violations, remain incomplete action-plan items as of the February and June 2026 FATF statements.

FIM-GAP-003 (D5): No Côte d&#x27;Ivoire-specific VASP registratio… FIM-GAP-003 (D5): No Côte d&#x27;Ivoire-specific VASP registration data, national crypto-asset regulatory framework, or dedicated CENTIF crypto-typology report was identified in open sources; regional (UEMOA/BCEAO) crypto-policy documentation is sparse relative to FATF/GIABA AML/CFT reporting reviewed for this baseline.

FIM-GAP-004 (D3): The 2023 GIABA Mutual Evaluation found cas… FIM-GAP-004 (D3): The 2023 GIABA Mutual Evaluation found cash confiscations at the border are not proportionate to the risks of a cash-intensive, largely informal economy with porous frontiers.

## Evidence

#### Confidence-tiered claims

Remains on FATF increased monitoring; action plan determined substantially complete June 2026; on-site assessment authorised; next Plenary decision 26-30 October 2026. [[Source 1]](#sec-sources)

Probable · 1 source

Substantially completed per FATF June 2026 Plenary determination; on-site verification mission conducted 8-10 September 2026. [[Source 1]](#sec-sources)

Probable · 1 source

Expected 26-30 October 2026. [[Source 1]](#sec-sources)

Uncertain · 1 source

PI-SPI connection mandatory for all UEMOA banks, EMIs and payment institutions from 30 September 2026; new fee cap effective 2 November 2026. [[Source 1]](#sec-sources)

Probable · 1 source

Active in CI but not licensed, regulated or supervised, for want of an operative licensing gateway, despite Art.58 of the UEMOA uniform AML law requiring prior authorisation. [[Source 1]](#sec-sources)

Probable · 1 source

No international sanctions regime currently in force against Cote d&#x27;Ivoire; the 2016 OFAC/UN sanctions program was terminated. [[Source 1]](#sec-sources)

Probable · 1 source

Casinos, including internet casinos, and gaming establishments including the national lottery, are designated DNFBPs/EPNFD subject to Côte d&#x27;Ivoire&#x27;s AML/CFT regime. [[Source 1]](#sec-sources)

Probable · 1 source

Ordonnance n°2023-875 (23 Nov 2023) repeals and replaces Loi n°2016-992 and transposes the UEMOA uniform AML/CFT law into Ivorian law. [[Source 1]](#sec-sources)

Probable · 1 source

Wave Mobile Money&#x27;s Ivorian subsidiary launched Wave Bank Africa S.A. in Abidjan with 20bn FCFA (~$32M) start-up capital, following a €117M debt-financing round closed June 2025. [[Source 1]](#sec-sources)

Probable · 1 source

Côte d&#x27;Ivoire&#x27;s state investment fund (CDC-CI) confirmed on 31 December 2025 a stake acquisition in Abidjan fintech Green Pay, alongside existing shareholder Orange Côte d&#x27;Ivoire Participations. [[Source 1]](#sec-sources)

Probable · 1 source

FATF&#x27;s June 2026 plenary determined Côte d&#x27;Ivoire had substantially completed its AML/CFT action plan and warranted an on-site assessment. [[Source 1]](#sec-sources)

Probable · 1 source

GIABA&#x27;s June 2026 3rd Enhanced Follow-Up Report upgraded Recommendation 24 (beneficial ownership of legal persons) from partially-compliant to largely-compliant. [[Source 1]](#sec-sources)

Probable · 1 source

BCEAO opened applications (14 Oct-30 Nov 2026) for its first fintech regulatory-sandbox cohort, explicitly excluding crypto-assets; a successful test does not confer authorisation. [[Source 1]](#sec-sources)

Probable · 1 source

The GIABA Plenary adopted the Mutual Evaluation Report (MER) of Côte d&#x27;Ivoire in June 2023. [[Source 1]](#sec-sources)

Probable · 1 source

US State Department confirms June 2026 FATF determination that Côte d&#x27;Ivoire substantially completed its action plan and warranted on-site assessment. [[Source 1]](#sec-sources)

Probable · 1 source

Ivorian justice system has opened over 1,000 money-laundering case files, as part of grey-list exit strategy. [[Source 1]](#sec-sources)

Probable · 1 source

2026-10-30 [[Source 1]](#sec-sources)

Probable · 1 source

True [[Source 1]](#sec-sources)

Probable · 1 source

True [[Source 1]](#sec-sources)

Probable · 1 source

removed_from_list [[Source 1]](#sec-sources)

Probable · 1 source

listed_still_in_force_despite_fatf_delisting [[Source 1]](#sec-sources)

Probable · 1 source

crypto_asset_projects_excluded_from_LIF_BCEAO_first_cohort [[Source 1]](#sec-sources)

Probable · 1 source

improved_verification_and_access_cited_in_fatf_delisting [[Source 1]](#sec-sources)

Probable · 1 source

introduced_2023-11-23_underpinning_fatf_reforms [[Source 1]](#sec-sources)

Probable · 1 source

FATF credits improved verification and access to basic and beneficial ownership information as part of action-plan closure [[Source 1]](#sec-sources)

Probable · 1 source

GIABA follow-up continues; last Follow-Up Report (31 May 2026) predates the October 2026 delisting and has not yet been updated to reflect it [[Source 1]](#sec-sources)

Probable · 1 source

decreasing [[Source 1]](#sec-sources)

Probable · 1 source

Welcomed the FATF decision as reflecting institutional, legislative, regulatory and operational reform [[Source 1]](#sec-sources)

Probable · 1 source
