--- title: "Senegal (SN) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/senegal/ source_html: /jurisdictions/senegal/index.html description: "Financial integrity intelligence for Senegal (SN): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 5f7e2d4be36defaccfe4cd1b189dddb0562cabd5346eaf4c393d5707bd3190a6 generator: "fe-fleet/md-twin@1.0" --- # Senegal (SN) — 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 “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Senegal SN Domains covered 8 of 8 Sources 135 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Compliant Tier: B Risk direction: Stable Enablement vs enforcement: Mixed Senegal's AML/CFT regime rests on Uniform Law No. More 2024-08 (14 Feb 2024), transposing UEMOA/WAEMU Directive 01/2023 and replacing the 2018-03 Act. CENTIF is the FIU; GIABA (FATF-style regional body) conducts mutual evaluations; BCEAO provides regional monetary/prudential oversight across eight UEMOA states. Senegal exited FATF's increased-monitoring list in October 2024 and the EU's high-risk third-country list in June 2025 after a 2021-2024 action plan. Key deficiencies - DNFBP risk-based supervision and sanctioning remain under-resourced despite legislative reform - Beneficial ownership transparency for complex offshore-linked extractive-sector deals (oil, gas, gold) remains structurally weak - No dedicated virtual asset service provider (VASP) licensing/AML regime identified for Senegal or the wider UEMOA bloc - Large cash-based informal economy limits transaction-monitoring visibility - NPO sector risk-based supervision for TF abuse still maturing Recent developments (18m) - FATF removed Senegal from the 'Jurisdictions under Increased Monitoring' grey list (25 October 2024) after a 2021 action plan - GIABA's 2024 Follow-Up Report (published 23 Apr 2025) credited Act 2024-08 with resolving most technical-compliance deficiencies - EU Commission delisted Senegal from its AML high-risk third-country list via Delegated Regulation (EU) 2025/1184 (10 June 2025) - Woodside Energy filed tax arbitration against Senegal over the Sangomar oil project amid increased state scrutiny of resource contracts (3 June 2025) - UNODC and Senegalese authorities (CENTIF, Justice, Defense, Security ministries) ran a June 2025 Dakar capacity-building programme on the terrorism-organised crime financing nexus - Senegal's National Assembly narrowed economic-crime conviction criteria that disqualify presidential candidates (April 2026) - Next GIABA 5th-round on-site mutual evaluation of Senegal expected around September 2026 Brief ## Lead signal #### Lead Signal Senegal's anti-money-laundering and counter-terrorist-financing architecture remains anchored on the standing regime established by Loi n deg 2024-08 du 14 fevrier 2024 relative a la lutte contre le blanchiment de capitaux, le financement du terrorisme et de la proliferation des armes de destruction massive (LBC/FT/PADM), which extends reporting-entity obligations to virtual-asset service providers and places supervision in the hands of the national financial intelligence unit, CENTIF. This is the durable backdrop against which the current evaluation cycle is being read, rather than a fresh development in itself. The more time-bound element this cycle is procedural: Senegal is mid-way through a third-round Mutual Evaluation conducted by the Inter-Governmental Action Group against Money Laundering in West Africa, a process that began on 9 January 2026, included an on-site visit between 10 and 28 August 2026, and is expected to run through to May 2027 with the Mutual Evaluation Report anticipated for adoption by the GIABA Plenary thereafter. Read full brief #### Lead Signal Senegal's anti-money-laundering and counter-terrorist-financing architecture remains anchored on the standing regime established by Loi n deg 2024-08 du 14 fevrier 2024 relative a la lutte contre le blanchiment de capitaux, le financement du terrorisme et de la proliferation des armes de destruction massive (LBC/FT/PADM), which extends reporting-entity obligations to virtual-asset service providers and places supervision in the hands of the national financial intelligence unit, CENTIF. This is the durable backdrop against which the current evaluation cycle is being read, rather than a fresh development in itself. The more time-bound element this cycle is procedural: Senegal is mid-way through a third-round Mutual Evaluation conducted by the Inter-Governmental Action Group against Money Laundering in West Africa, a process that began on 9 January 2026, included an on-site visit between 10 and 28 August 2026, and is expected to run through to May 2027 with the Mutual Evaluation Report anticipated for adoption by the GIABA Plenary thereafter. Taken together, these two facts describe a jurisdiction in a holding pattern that is itself analytically meaningful. Senegal exited the FATF grey list in October 2024 and has remained off it since; the present evaluation is the mechanism by which that status will be tested afresh, not a signal that the status is already in question. No interim finding from the evaluation has been published, and the press reporting underlying the regime description is itself secondary rather than a reading of the primary instrument text. #### Other Developments No sanctions, beneficial-ownership, enabler-jurisdiction, conflict-finance, crypto-integrity or commercial-activity finding specific to Senegal surfaced in the window under review. This silence is recorded here as a description of the evidence actually gathered this cycle, not as a judgment that these areas are quiet or stable in Senegal as a matter of fact; the evaluation record available does not yet reach that question in any direction. #### Cross-Monitor Connections The virtual-asset-service-provider obligations folded into Loi n deg 2024-08 give CENTIF a supervisory claim over crypto-asset operators that sits adjacent to the regional digital-asset rulemaking tracked for West Africa's payments architecture, where the regional central bank has continued to describe crypto-asset regulation as a work in progress rather than a settled framework. Where Senegal's own payments-sector reforms create new e-money thresholds and interoperable-transfer routing, the AML/CFT reporting perimeter that CENTIF administers is the mechanism through which the illicit-finance exposure of those same instruments would, in principle, be surfaced — a structural linkage rather than an incident-level one, and one the evaluation now under way may clarify or complicate depending on its findings. #### Outlook The material event to watch is the GIABA Plenary's adoption of the third-round Mutual Evaluation Report, expected as scheduled for 2027 following the August 2026 on-site visit, though the precise timing within that window should be treated as unsettled rather than fixed. The outcome will determine whether Senegal's AML/CFT regime is assessed as having kept pace with the FATF standard since its 2018 Mutual Evaluation Report and its 2024 grey-list exit, or whether gaps are identified that could reopen monitoring questions. Until that report is adopted, Senegal's standing regime of record — Loi n deg 2024-08 administered by CENTIF — remains the operative description of the national framework, and the absence of findings elsewhere in the typology set should be read as a gap in the evidence gathered this cycle, not as a confirmed absence of activity. Earlier periodic briefs (6) 3 Nov 2026 · fim-2026-11-03 #### Lead Signal Senegal's anti-money-laundering and counter-terrorist-financing architecture remains anchored on the standing regime established by Loi n deg 2024-08 du 14 fevrier 2024 relative a la lutte contre le blanchiment de capitaux, le financement du terrorisme et de la proliferation des armes de destruction massive (LBC/FT/PADM), which extends reporting-entity obligations to virtual-asset service providers and places supervision in the hands of the national financial intelligence unit, CENTIF. This is the durable backdrop against which the current evaluation cycle is being read, rather than a fresh development in itself. The more time-bound element is procedural: Senegal is mid-way through a third-round Mutual Evaluation conducted by the Inter-Governmental Action Group against Money Laundering in West Africa, a process that began on 9 January 2026, included an on-site visit between 10 and 28 August 2026, and is expected to run through to May 2027 with the Mutual Evaluation Report anticipated for adoption by the GIABA Plenary thereafter. Taken together, these two facts describe a jurisdiction in a holding pattern that is itself analytically meaningful. Senegal exited the FATF grey list in October 2024 and has remained off it since; the present evaluation is the mechanism by which that status will be tested afresh, not a signal that the status is already in question. No interim finding from the evaluation has been published, and the press reporting underlying the regime description is itself secondary rather than a reading of the primary instrument text. #### Other Developments No sanctions, beneficial-ownership, enabler-jurisdiction, conflict-finance, crypto-integrity or commercial-activity finding specific to Senegal surfaced in the window under review. This silence is recorded here as a description of the evidence actually gathered, not as a judgment that these areas are quiet or stable in Senegal as a matter of fact; the evaluation record available does not yet reach that question in any direction. #### Cross-Monitor Connections The virtual-asset-service-provider obligations folded into Loi n deg 2024-08 give CENTIF a supervisory claim over crypto-asset operators that sits adjacent to the regional digital-asset rulemaking tracked for West Africa's payments architecture, where the regional central bank has continued to describe crypto-asset regulation as a work in progress rather than a settled framework. Where Senegal's own payments-sector reforms create new e-money thresholds and interoperable-transfer routing, the AML/CFT reporting perimeter that CENTIF administers is the mechanism through which the illicit-finance exposure of those same instruments would, in principle, be surfaced — a structural linkage rather than an incident-level one, and one the evaluation now under way may clarify or complicate depending on its findings. #### Outlook The material event to watch is the GIABA Plenary's adoption of the third-round Mutual Evaluation Report, expected as scheduled for 2027 following the August 2026 on-site visit, though the precise timing within that window should be treated as unsettled rather than fixed. The outcome will determine whether Senegal's AML/CFT regime is assessed as having kept pace with the FATF standard since its 2018 Mutual Evaluation Report and its 2024 grey-list exit, or whether gaps are identified that could reopen monitoring questions. Until that report is adopted, Senegal's standing regime of record — Loi n deg 2024-08 administered by CENTIF — remains the operative description of the national framework, and the absence of findings elsewhere in the typology set should be read as a gap in the evidence gathered, not as a confirmed absence of activity. 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Senegal's anti-money-laundering and counter-terrorist-financing regime moved into a new evaluative phase, with the regional body for West Africa, GIABA, conducting an on-site assessment mission from 10 to 28 August 2026 as part of its third-round mutual evaluation methodology. Plenary adoption of the resulting report is targeted for May 2027. This is an architecture-level development rather than an incident: Senegal's regime of record, Loi n2024-08 du 14 fevrier 2024, which extends obliged-entity scope to virtual-asset service providers and designates CENTIF as the financial intelligence unit, remains unchanged in substance, but the evaluation process itself is actively testing the effectiveness of that framework against a third-round methodology that sets a materially higher bar than the second-cycle assessment Senegal previously faced. Senegal continues to sit outside the FATF increased-monitoring list, a status it has held since exiting in October 2024, and no adverse interim signal has emerged to disturb that standing position. The combination of a stable headline sanctions status and an actively progressing mutual evaluation is the structural story: the institutional architecture is being tested even as the formal designation record stays quiet. #### Other Developments Beneficial-ownership transparency in the extractive sector drew external recognition. Senegal's extractive-industries beneficial-ownership register, opened to unconditional public access under a 2025 decree, was cited when Senegal won the EITI Chair's Award 2026 on 8 October 2026, reported alongside a validation score of 89 out of 100. This register remains sector-limited to extractive industries rather than constituting an economy-wide corporate beneficial-ownership database, a distinction worth holding onto even as the award signals credible sectoral progress. The technical-compliance questionnaire response was submitted in January 2026. CENTIF's own account of the mutual-evaluation process records transmission of its response to the Technical Compliance Questionnaire on 9 January 2026, which forms part of the documentary record feeding into the August on-site mission and the planned 2027 plenary. #### Cross-Monitor Connections The extractive-sector beneficial-ownership transparency development has a natural read-across to broader corporate-transparency and conflict-finance monitoring work elsewhere in the fleet, given that extractive-industry revenue flows are a recurring vector for both legitimate fiscal transparency gains and, where registers remain narrow, for opacity in adjacent corporate structures. No direct crypto-asset or payments-infrastructure finding surfaced that would warrant a cross-reference into those adjacent monitoring lines for Senegal specifically. #### Outlook The period leading into the targeted May 2027 GIABA plenary will likely be the dominant axis of movement for Senegal's standing in this regime: the effectiveness findings from the August 2026 on-site mission will determine whether the current compliant technical rating on recommendations such as Recommendation 7 is matched by a credible effectiveness record, and that outcome carries more structural weight than any single enforcement action would. The extractive-sector beneficial-ownership register's public-access status is expected to remain a stable, positively-regarded feature of Senegal's transparency profile, though whether that sectoral model extends to an economy-wide corporate register remains an open structural question not yet addressed by any instrument identified. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal The most consequential development touching Senegal this cycle is not a change to the countrys anti-money-laundering architecture but a payments-infrastructure mandate issued by the regional central bank. The Banque Centrale des Etats de lAfrique de lOuest (BCEAO) has made use of its PI-SPI instant-payment platform mandatory for interoperable e-money transactions across the West African Economic and Monetary Union (UEMOA) from 2 November 2026, accompanied by a revised fee schedule. Senegal hosts the largest national share of connected participants of any member state, 43 of the 175 entities now linked to the platform, which places the countrys e-money sector at the centre of a region-wide shift from a voluntary interoperability arrangement toward a compulsory one. A secondary report, not yet independently verified against the instruction's own published text, indicates that an accompanying instrument, BCEAO Instruction n°020 of 8 October 2026, raises the e-money wallet ceiling to XOF 4,000,000 per client per issuer and the monthly top-up cap to XOF 15,000,000, both effective the same date. Taken together, the platform mandate and the reported ceiling increase describe a regional payments regulator simultaneously tightening the operating rules for e-money issuance (through compulsory platform use and a new fee structure) and loosening the consumer-facing transaction limits that have constrained e-money usage. This is an architecture-level development in the commercial-activity domain rather than an enforcement incident, and it arrives without any accompanying change to Senegals underlying AML/CFT legal framework. #### Other Developments Senegals AML/CFT regime remains assessed as structurally solid. Senegal continues to be governed by Loi n°2024-08 du 14 février 2024 relative a la lutte contre le blanchiment de capitaux, le financement du terrorisme et de la proliferation des armes de destruction massive (LBC/FT/PADM), with CENTIF as the designated financial intelligence unit. GIABAs sixth Enhanced Follow-Up Report, issued in September 2026, confirms that the country has put in place a solid legislative framework. Senegal remains off both the FATF grey list, from which it was removed at the 25 October 2024 plenary, and the EU list of high-risk third countries, from which it was removed on 10 June 2025, notwithstanding that some lower-tier aggregator sources continue to list it incorrectly as grey-listed. CENTIF reports a persistent analytical-capacity gap. The FIUs own 2024 activity report notes ongoing staff-training needs on complex financial-data analysis. This is a standing observation rather than a new finding, but it sits in some tension with the increasingly active-compliance-technology expectations that FATF-aligned supervisors are articulating for FIUs across the region, including one now overseeing a materially larger volume of interoperable e-money flows under the PI-SPI mandate. Regional crypto-asset regulation remains unset. The WAEMU C-CRYPTO drafting committee continues its work with no announced timeline, per BCEAO Governor Jean-Claude Kassi Brous 22 July 2026 statement that the framework remains in preparation. #### Cross-Monitor Connections The PI-SPI mandate and the reported e-money ceiling increase are structural payments-infrastructure developments that are also live findings for the World Payments Monitor, which assesses them directly for licensing, corridor and commercial-intelligence implications. Readers focused on the financial-integrity dimension of this development should note the connection without expecting independent AML analysis of the platform migration itself here; the compliance question raised for this monitor is one of supervisory bandwidth, not of a new typology or illicit-finance channel, since the instrument is a payments-interoperability and prudential measure rather than an AML/CFT rule change. #### Outlook As the PI-SPI mandate and reported ceiling changes take effect from 2 November 2026 as scheduled, the practical test will be whether CENTIFs supervisory and analytical capacity, already flagged internally as needing further training investment, keeps pace with a payments ecosystem being pushed toward higher transaction volumes and higher per-client limits at the same time. No change to Senegals underlying AML/CFT legislative framework is indicated, and the countrys standing outside both the FATF and EU risk lists is expected to continue absent a reversal at a future plenary or Commission review. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Senegal's financial-integrity posture this cycle is dominated by an architecture-level regional change rather than enforcement activity. BCEAO's Instruction n°020, amending the core e-money instrument (Instruction n°008-05-2015), doubles the per-client e-money balance ceiling from FCFA 2 million to FCFA 4 million and raises the monthly cumulative top-up ceiling from FCFA 10 million to FCFA 15 million, effective 2 November 2026 across WAEMU including Senegal. A client wishing to exceed these ceilings requires prior BCEAO authorisation stating grounds, duration, amount and enhanced control measures. The widening of the value threshold available on Senegal's dominant mobile-money rails before enhanced scrutiny applies is a structural change to the exposure surface for the country's payment-company and bank e-money issuers, reported convergently across regional press though no primary BCEAO instrument text was independently retrieved this cycle. #### Other Developments Senegal's AML law continues to bring virtual-asset service providers into reporting scope. Loi n°2024-08 of 14 February 2024 extends AML/CFT reporting-entity obligations to 'Prestataires de services d'actifs virtuels' (PSAV), a standing national anchor that sits apart from, and ahead of, the regional BCEAO crypto-asset licensing gap. Senegal remains outside the FATF increased-monitoring list , having exited in October 2024, a status unchanged this cycle. GIABA's third-round mutual evaluation on-site assessor visit for Senegal ran from 10 to 28 August 2026 , positioning a new mutual evaluation report for a future plenary. A dedicated WAEMU crypto-asset regulatory framework, drafted by BCEAO's C-CRYPTO committee and modelled on comparable international approaches, remains in preparation with no confirmed publication date as of BCEAO's most recent statement in July 2026; no national or regional crypto-asset licensing regime exists in the interim. The PI-SPI interoperable instant-payment platform reached 175 authorised participants across WAEMU as of its 30 September 2026 published list, with Senegal forming the largest single-country cohort, a development relevant to the AML monitoring surface given the expanding interoperability of payment rails. #### Cross-Monitor Connections The BCEAO e-money ceiling increase is the same instrument tracked by world-payments for its effect on e-money issuer licensing and market access, and by crypto for establishing what the instrument does not reach, namely crypto-asset stablecoins. From a financial-integrity perspective, the ceiling increase is read as widening the AML exposure surface on mobile-money rails rather than as a market-access or product story: a doubled per-client balance ceiling means a greater value can move through an e-money account before the enhanced-scrutiny or authorisation trigger engages, which is directly relevant to transaction-monitoring thresholds and suspicious-activity detection design for obliged payment-company and bank entities operating in Senegal. #### Outlook The BCEAO ceiling increase takes effect 2 November 2026 and is the clearest near-term date against which Senegal's AML exposure surface should be reassessed; until a primary BCEAO instrument text is retrieved, confidence in the precise terms rests on convergent secondary reporting. Separately, the outcome of the GIABA third-round mutual evaluation, whose on-site visit concluded in August 2026, will be the next material marker of Senegal's assessed AML/CFT effectiveness once a report reaches plenary; and the BCEAO C-CRYPTO committee's still-unscheduled publication remains the variable that would close the current regional crypto-asset licensing gap. 6 Sep 2026 · fim-2026-09-05 #### Lead Signal Senegal's beneficial-ownership transparency regime is scaling substantially, though within a still-narrow sectoral boundary. Extractive-sector beneficial-ownership declarations rose from thirteen companies in 2021 to six hundred twenty-eight in 2024, an increase attributed to Presidential Decree No. 2020-791 and corroborated across two independent Open Ownership pages, at an assessed confidence tier, though no primary government-gazette text for the decree itself was reached this cycle. The scale of that increase is itself the signal, independent of any single enforcement event: it indicates that a sector-specific disclosure obligation, once it existed on paper, has been substantially taken up in practice over a three-year window. The reform is running against an external clock: ECOWAS Directive C/DIR.2/07/23 requires Senegal to operate a central, cross-sector beneficial-ownership register by 1 January 2027, a deadline that falls within the half-year uncertainty band the Interpreter assigned this cycle. That directive forces a structural transition, since the current regime is sector-limited to extractives and, per the underlying reporting, lacked public-access and enforcement provisions until recently. #### Other Developments OFNAC broadens asset declarations and moves toward public compliance naming. Senegal's anti-corruption body will begin publishing provisional lists of compliant and non-compliant officials from 10 August 2026, a low-confidence finding resting on a single tier-three source not yet corroborated against OFNAC's own site. The underlying 2025 reform lowered the budget-manager declaration threshold from CFA one billion to CFA five hundred million and broadened the filer pool to include prosecutors, judges, and state-owned-enterprise heads, alongside strengthened criminal sanctions. The analytical significance sits in the test the reform now faces: publishing names of non-compliant senior officials is materially different from passing the underlying statute, and this cycle's evidence cannot yet confirm whether the naming mechanism will be applied in practice. BCEAO accelerates work toward a regional crypto-asset framework. The regional central bank is intensifying engagement with crypto-sector actors and preparing a UEMOA-wide regulatory framework for digital assets, a low-confidence finding sourced to a single tier-four commentary source this cycle. No general prohibition and no dedicated crypto statute currently exists for Senegal, leaving activity in a legal grey zone pending the regional framework's finalisation. #### Cross-Monitor Connections OFNAC's broadened asset-declaration and public-naming regime carries a state-capture-adjacent dimension: an asset-declaration regime that names non-compliant senior officials, if implemented as designed, would generate a public record of elite non-disclosure that a state-capture-focused monitor would want to track independently rather than have re-analysed here. Separately, BCEAO's crypto-framework preparation sits at the edge of a financial-innovation and payments-infrastructure boundary that this brief does not extend into; the payments-system implications of that framework belong to a distinct monitor's domain. #### Outlook The central variable to watch is implementation, not legislation. On beneficial ownership, the test is whether Senegal's central, cross-sector register materialises on or near the January 2027 ECOWAS deadline, and whether the extractive-sector public-access gap the underlying reporting flags is closed alongside the sectoral expansion. On asset declarations, the test is whether OFNAC's first published compliance list, due from 10 August 2026, actually names senior officials rather than settling into a symbolic gesture. On crypto, the test is whether BCEAO's preparatory dialogue converts into a binding UEMOA-wide statute this cycle or the next, since the current grey-zone status leaves both compliance exposure and enforcement posture genuinely undetermined for any crypto-asset actor operating in or through Senegal. 6 Aug 2026 · fim-2026-08-05 #### Lead Signal Law n2024-08 of Senegal, promulgated 14 February 2024, repeals and replaces the 2018 AML/CFT statute of the country and transposes UEMOA Directive 01/2023 into domestic law, a reform confirmed across Tier-1 sourcing from GIABA, CENTIF Senegal, and the Ministry of Finance and Budget. The reform closes CDD and scope gaps that GIABA had previously identified in the framework of Senegal. Senegal was also removed from the FATF list of jurisdictions under increased monitoring in October 2024, an outcome this cycle can only assess rather than confirm at the highest tier, because no directly dated Tier-1 FATF statement was retrieved this cycle to sit alongside the Tier-3 press corroboration available. Read together, the statutory repeal-and-replace and the grey-list exit constitute the kind of structural, architecture-level movement this monitor privileges over any single enforcement episode: two institutionally distinct processes, domestic legislative reform and supranational mutual-evaluation follow-up, converged on the same underlying judgment that the enabling AML/CFT framework of Senegal has materially improved. That architecture-level improvement runs alongside a narrower and more qualified beneficial-ownership picture. Beneficial-ownership declarations in Senegal grew from 13 companies in 2021 to 628 in 2024, a scale shift credited to EITI and Opening Extractives-backed reform activity, but this growth sits inside a regulatory-collection system rather than a public register: no economy-wide, publicly searchable UBO register yet exists in Senegal. The ECOWAS Supplementary Act, Directive C/DIR.2/07/23, imposes a 1 January 2027 deadline for central beneficial-ownership registers across the bloc, and while the underlying directive text itself lacks a Tier-1 primary anchor this cycle, Senegal presents as a lead regional implementer by declaration volume ahead of that deadline. The gap between rising declaration volume and the continued absence of public disclosure is the analytically load-bearing fact here: statutory reform and grey-list exit describe the architecture, but whether that architecture becomes enforceable and inspectable at the point of use remains an open question the 2027 deadline will test directly. #### Other Developments A bounded but Tier-1-sourced banking-sector disciplinary action offsets the reform narrative. The WAMU Banking Commission issued a reprimand on 8 July 2024 against a bank based in Senegal for management shortcomings and regulatory breaches, an episodic action that does not itself alter the structural reading of the AML/CFT trajectory of Senegal but confirms that supervisory enforcement continues to operate against the banking sector of the country even as the legislative baseline improves. The most recent named licence-withdrawal actions of the commission this cycle targeted Niger- and Burkina Faso-based institutions rather than Senegal directly, a gap logged rather than treated as a clean result. A regional crypto-asset dialogue convened by BCEAO signals a pre-codification supervisory posture rather than a binding regime. BCEAO convened an international conference on crypto-assets and digital innovation, an early indication of WAEMU-wide interest in virtual-asset-service-provider supervision, but the finding rests on a single Tier-1 calendar entry without an accompanying operative regulation, and no binding Senegal-specific virtual-asset statute was located this cycle. The gap between regional dialogue and codified rule is itself the signal: a regulatory-gap window persists for crypto-facilitated flows across the UMOA zone while formal VASP supervision remains unbuilt. The sanctions posture of Senegal remains structurally narrow. Senegal maintains no autonomous sanctions list and implements United Nations Security Council sanctions only; no international sanctions are currently in force against Senegal. This finding is corroborated across compliance-reference aggregator sourcing rather than a primary sanctions-authority publication, a source-tier constraint the monitor logs rather than elevates past its assessed tier. #### Cross-Monitor Connections Beneficial-ownership data in Senegal is presently collected for regulatory use rather than published, and near four hundred companies operate in the extractive industries of the country against a historically opaque ownership backdrop; this combination is the kind of enabler-jurisdiction opacity that routes directly into the state-capture lens of WDM and the commodity-flow evasion tracking of ERM, since extractive-sector ownership concealment and conflict- or state-linked commodity flows share the same underlying corporate-opacity infrastructure. Distinct conflict-finance findings for Senegal were thin this cycle, which the monitor treats as a coverage gap rather than a clean assessment, consistent with the principle that absence of confirmed findings in a permissive information environment is itself worth flagging to SCEM for continued monitoring rather than closing out. #### Outlook The most consequential near-term test of the architecture-level reading produced this cycle is not legislative but evaluative: the mutual-evaluation follow-up cycle of GIABA continues, with a possible onsite window around September 2026 and plenary discussion of the resulting report projected around May 2027, and that process will assess whether the provisions of Law 2024-08 translate into demonstrated institutional reach rather than statutory text alone. Separately, the ECOWAS 1 January 2027 central beneficial-ownership register deadline is the second horizon marker: the declaration-volume growth of Senegal positions it as a lead regional implementer, but the absence of a public searchable register as of this cycle means the deadline itself, rather than any interim metric, is the point at which the beneficial-ownership picture will either close the gap between collection and disclosure or confirm it as a durable structural feature of the regime. The crypto-asset dialogue of BCEAO remains a posture rather than a rule, and whether WAEMU-wide VASP codification follows before the gap window closes is a further open signal worth carrying into subsequent cycles. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion Senegal maintains no autonomous sanctions list and implements United Nations Security Council sanctions only; no international sanctions are currently in force against Senegal. This finding is corroborated across compliance-reference aggregator sourcing rather than a primary sanctions-authority publication, a source-tier constraint the monitor logs at the assessed rather than confirmed tier. The standing-tracker review this cycle found no material Russia-sanctions-evasion architecture signal touching Senegal, and a parallel Yemen and Houthi-channel check also returned no material change for the country; the regime-divergence posture of Senegal, which tracks the gap between UN-only implementation and autonomous list-building seen elsewhere in the coverage of this monitor, likewise showed no movement this cycle. Continue reading Read through the enablement-as-signal principle this monitor applies throughout its coverage, the absence of designations or evasion-architecture findings for Senegal is not itself a clean result; it is a monitoring baseline that should be revisited as the broader AML/CFT architecture of Senegal strengthens under Law n2024-08. A narrower sanctions posture combined with an improving beneficial-ownership and customer-due-diligence framework changes the analytical stakes of any future designation gap, since improved domestic AML capacity in principle raises the cost of using Senegal as a third-country transit point for sanctions evasion, while the absence of an autonomous list leaves Senegal dependent entirely on the pace and scope of UN Security Council designations. The reprimand issued against a bank based in Senegal by the WAMU Banking Commission this cycle, while not itself a sanctions-nexus finding, illustrates that supervisory enforcement capacity exists within the regional banking architecture even where autonomous sanctions capacity does not, a distinction worth carrying forward into future-cycle assessments of enforcement-versus-enablement balance. The gap is logged transparently rather than filled with adjacent-domain material, consistent with the honesty-over-coverage standard of this monitor for thin-signal domains. #### Outlook The sanctions posture of Senegal is expected to remain structurally narrow and UN-only absent a change in regional UEMOA or national policy; the more consequential near-term variable is whether the improving AML/CFT statutory base of the country under Law 2024-08 begins to surface sanctions-adjacent findings, such as UN-list implementation gaps or third-country evasion transit, that were not visible to research conducted this cycle. This domain remains a watch item rather than an active-finding item, and the monitor will continue checking Russia, Iran, and DPRK-linked transit-risk signals against Senegal in subsequent cycles even where the baseline is currently stable. #### Beneficial Ownership and Corporate Transparency Senegal exited the FATF Jurisdictions under Increased Monitoring list on 25 October 2024, following the February 2021 GIABA action plan. GIABA subsequent Follow-Up Report, published 23 April 2025, re-rated Senegal Largely Compliant on Recommendations 16, 19, 22 and 23, crediting Uniform Law No. 2024-08. The European Commission delisted Senegal from the EU high-risk third-country AML list via Delegated Regulation (EU) 2025/1184, effective 10 June 2025, roughly eight months after the FATF action, alongside Barbados, Gibraltar, Jamaica, Panama, the Philippines, Uganda and the United Arab Emirates. UK HM Treasury alignment with the FATF delisting is presumed per standard practice, though the exact removal date is not independently confirmed this baseline, a gap logged for the regime-divergence tracker. Continue reading As standing structural backdrop against which this cycle Senegal signal is read: the EU AML Package is not one instrument but three distinct ones. The AML Regulation, or AMLR (Regulation (EU) 2024/1624), is directly applicable across EU Member States without domestic transposition. The sixth AML Directive, or 6AMLD, requires transposition by each Member State individually. The AMLA Regulation (Regulation (EU) 2024/1620) establishes the Anti-Money Laundering Authority, which will assume direct supervision of a defined set of high-risk cross-border obliged entities and indirect supervisory-coordination authority over the remainder, shifting the perimeter from a purely national supervisory model toward a hybrid EU-level regime as AMLR reaches full application. Senegal, as a non-EEA jurisdiction, sits entirely outside this architecture in a supervisory sense; its sole EU nexus is the Article 9 high-risk third-country delegated-act mechanism, from which it was delisted in June 2025. The interpreter regulatory horizon anchors this cycle indicate that once AMLR is fully applied and AMLA supervisory architecture matures, expected around 2027, the methodology governing that third-country list is expected to migrate toward AMLA-informed processes, a development that could alter future re-listing thresholds for Senegal without bringing it inside the direct-supervision perimeter itself. The technical-compliance narrative, however, sits uneasily against the Petro-Tim Ltd and Timis Corp offshore concession architecture. Layered shell vehicles registered in the Cayman Islands and British Virgin Islands, linked to a presidential-family politically exposed person, acquired Senegalese offshore oil blocks and subsequently flipped them to Kosmos Energy and BP for hundreds of millions of dollars plus multi-billion-dollar royalty streams. No confirmed prosecution or asset recovery has resulted. The analytical unit is the corporate layering and PEP nexus itself, not any single transaction, and it is corroborated across OCCRP, Global Witness and Bloomberg reporting. GIABA credits Senegal with maintaining adequate basic and beneficial-ownership information on paper, but the Petro-Tim case demonstrates limited practical reach into complex offshore-layered extractive-sector ownership, and no independent BO-effectiveness audit has been located to resolve the gap between formal record-keeping and operational transparency. Outstanding secondary legislation compounds the effectiveness question. GIABA flagged minor deficiencies, including an undefined CDD information list and unresolved third-country equivalence criteria, requiring implementing decrees expected during 2026. These are forward-looking obligations whose citation stage remains proposed rather than in force, and their resolution ahead of the GIABA 5th-round on-site mutual evaluation, expected around September 2026, will materially affect whether Senegal Largely Compliant ratings hold under effectiveness testing rather than technical-compliance review alone. #### Outlook The defining test for Senegal D2 trajectory is the GIABA 5th-round on-site mutual evaluation expected around September 2026, with plenary discussion of the resulting report projected around May 2027. That evaluation will assess whether Uniform Law No. 2024-08 functions in practice, particularly on beneficial-ownership effectiveness in extractive-sector transactions, rather than simply whether the statute exists. Separately, the AMLR/AMLA methodology migration expected around 2027 is a genuine but uncertain horizon signal, assessed here at Possible confidence, that could reshape how the EU determines third-country risk status for jurisdictions like Senegal going forward. Firms with Senegal-linked exposure should treat the current delisted status as provisional pending both tests, rather than as a settled clean determination. #### Enabler Jurisdictions and Professional Facilitators Senegal enabler architecture this cycle presents as mixed: a structurally improving legislative framework paired with persistent enforcement-capacity gaps and a discrete state-capture risk indicator. Despite Act 2024-08 strengthening DNFBP obligations in statute, GIABA and FATF assessments continue to identify under-resourced risk-based supervision and sanctioning of lawyers, real-estate agents and precious-metals dealers as a persistent gap. The binding constraint, corroborated by both the GIABA Mutual Evaluation and Follow-Up Report, is enforcement capacity rather than legislative text; a large cash-based informal economy further limits the transaction-monitoring visibility that would otherwise flag suspicious DNFBP activity. Continue reading The cross-border enabler chain behind Senegal single most significant BO-opacity case runs through named offshore jurisdictions rather than through Senegal itself. Cayman Islands and British Virgin Islands vehicles, alongside United Kingdom and Australia-linked intermediaries, were named in the Petro-Tim Ltd and Timis Corp offshore oil-concession architecture, which used layered shell structures tied to a presidential-family PEP to acquire and flip Senegalese oil blocks for hundreds of millions of dollars plus multi-billion-dollar royalty streams. This is the architecture-over-incident lesson for the enabler-jurisdiction domain: no single Senegalese regulatory failure produced this outcome, rather a well-worn cross-border professional-facilitator chain routed through jurisdictions with far more developed AML frameworks than Senegal own. A separate and more Senegal-specific enabler signal concerns political-accountability architecture rather than corporate-services architecture. In April 2026, Senegal National Assembly narrowed the range of criminal convictions disqualifying presidential candidates, limiting ineligibility largely to economic crimes such as corruption and embezzlement, in a context where the sitting Prime Minister had previously faced multiple related charges. Applying the F1 state-capture filter, this is assessed as a legislative narrowing of a PEP-accountability mechanism, a structural risk indicator rather than confirmed capture of the financial architecture. The finding rests on a single tier-2 source and is held at Assessed rather than High confidence pending corroboration, consistent with the honesty-over-coverage principle that governs this domain assessment. A parallel state-integrity signal, distinct from the enabler-jurisdiction finding proper but relevant to the same institutional-capacity picture, is the debt and deficit misreporting identified by an audit commissioned by Senegal incoming government: public debt-to-GDP averaged 76.3 percent versus 65.9 percent previously reported, with a budget deficit near double the stated figure, triggering a sovereign downgrade and IMF Extended Credit Facility suspension. This is a state-integrity failure mode adjacent to money-laundering risk, and it undermines confidence in the macro-financial data that underpins broader AML/CFT risk assessment for the jurisdiction. #### Outlook The enabler-jurisdiction picture for Senegal is unlikely to resolve cleanly in either direction before the GIABA 5th-round on-site mutual evaluation expected around September 2026, which will test whether DNFBP supervisory capacity has genuinely improved or merely been legislated. The April 2026 candidate-eligibility narrowing warrants continued F1 monitoring as a state-capture risk indicator, particularly given its timing relative to the Prime Minister prior legal exposure, though it remains Assessed rather than High confidence pending further corroboration. The offshore-jurisdiction dimension of this domain, meanwhile, is a reminder that enabler-jurisdiction assessment cannot be confined to the targeted jurisdiction alone; Cayman, BVI, UK and Australian intermediary conduct in the Petro-Tim case is as much a D3 finding as anything occurring within Senegal borders. #### Conflict Finance and Extractive-Industry Integrity Senegal functions in this domain primarily as a conflict-finance transit corridor rather than as a primary source or policy-driven enabler jurisdiction, and the structural risk is tied to regional Sahel instability rather than to any domestic Senegalese choice to permit illicit flows. The clearest evidence is geographic: approximately 98 percent of Senegal artisanal gold mining occurs in the Kedougou region, directly on the Mali border, and gold from this region moves through informal cross-border networks that intersect Sahelian jihadist taxation economies before entering downstream refining and export channels with limited chain-of-custody documentation. Two independent tier-1 institutional sources, UNODC and OFAC, corroborate this corridor pattern, which mirrors the broader Sahel gold-trafficking architecture already documented across the region by both bodies. Continue reading A parallel and equally structural finding concerns terrorism financing rather than commodity laundering specifically. Senegal porous borders with Mali and Burkina Faso, its large informal cash economy, and its unlicensed remittance channels together create a pathway for terrorist-recruitment financing and fighter-travel fund transfers into Sahelian conflict zones. GIABA has documented prosecuted cases reflecting this dynamic, applying the F4 source-channel-deployment trace that this filter requires: the source is diaspora and domestic informal-economy cash, the channel is unlicensed remittance infrastructure, and the deployment is fighter travel and recruitment support into neighbouring conflict zones. In direct institutional response, a June 2025 UNODC-CENTIF programme in Dakar trained 22 officials, including CENTIF staff, to strengthen investigation and prosecution capacity for the terrorism-organised-crime financing convergence, though this is a capacity-building action rather than an enforcement outcome, and no direct prosecutions resulted from the training itself. A secondary, extractive-sector thread runs in parallel to the conflict-finance corridor findings. Woodside Energy filed international arbitration against the Government of Senegal over the Sangomar offshore oil project fiscal terms, amid intensified state scrutiny of resource contracts, a dispute that remained unresolved as of mid-2025. While this arbitration is not itself a conflict-finance or terrorism-financing matter, it sits within the same extractive-contract-transparency friction that also produced the Petro-Tim precedent, and it is corroborated by only a single tier-2 source, warranting Assessed rather than High confidence. #### Outlook The conflict-finance picture for Senegal is likely to remain stable in trajectory rather than escalating or de-escalating sharply, because the underlying driver is regional Sahel instability rather than a domestic Senegalese policy lever that could shift quickly. Continued UNODC-CENTIF capacity-building work is the most probable near-term development to watch, alongside any further prosecutions arising from the training delivered in June 2025. The Woodside Sangomar arbitration remains an open, separately-tracked extractive-contract dispute whose resolution will be a secondary but relevant indicator of Senegal broader approach to resource-contract transparency. #### Crypto, Digital Assets, and Financial Innovation Senegal digital-asset regulatory picture is defined this cycle by absence rather than by any documented enforcement action or scheme. No dedicated national or WAEMU/UEMOA-wide virtual-asset-service-provider licensing or AML regime has been identified for Senegal. Mobile-money platforms, principally Wave and Orange Money, remain the dominant digital-value channel domestically, ahead of cryptocurrency. This finding is drawn from regional Sub-Saharan Africa Chainalysis analytics rather than Senegal-specific sourcing, a genuine sourcing-thinness constraint on this cycle D5 coverage that is logged honestly rather than papered over; regional on-chain value is reported up approximately 52 percent year over year, but Senegal is not named among the leading national crypto markets within that regional dataset. Continue reading Applying the enablement-as-signal principle that governs this domain, the absence of a VASP regulatory framework is itself the analytically relevant finding, not merely a data gap. A jurisdiction with no dedicated crypto AML regime has, by construction, no ability to apply targeted CDD, travel-rule, or sanctions-screening obligations to virtual-asset activity occurring within or transiting through its borders, regardless of current transaction volume. Current exposure appears comparatively low given mobile-money dominance over crypto within Senegal specifically, but this is a forward vulnerability rather than a present-tense exploitation pattern, and it should be read as such: a regulatory gap that could become materially significant if regional crypto adoption trends, which are reported growing, extend into Senegal at a faster rate than any UEMOA-level regulatory response. #### Outlook This domain is held at Possible confidence and limited_signal status this cycle, honestly reflecting thin, regional-only sourcing rather than a Senegal-specific regulatory analysis. The most valuable next development to watch is any UEMOA-level or BCEAO announcement of a dedicated VASP framework, which would materially change this domain assessment; absent that, continued monitoring of regional crypto-adoption trend data as a leading indicator of Senegal-specific exposure risk is the appropriate posture. No enforcement action or specific scheme within Senegal digital-asset space has been identified this cycle. #### Compliance Technology and Active Defence No material RegTech, supervisory-technology, or active-defence development specific to the compliance-technology posture of Senegal was identified this cycle. This domain is explicitly exempt from the substantive-finding floor applied elsewhere in the coverage of this monitor, and the absence of findings here should be read as a genuine research gap rather than a confirmed stable baseline; Low confidence is assigned to the corresponding key judgment for that reason. The gap is logged transparently rather than filled with adjacent-domain material, consistent with the honesty-over-coverage standard of this monitor for thin-signal domains. Continue reading The closest adjacent signal available this cycle is the regional crypto-asset and digital-innovation conference of BCEAO, discussed under the crypto and digital-assets domain, which touches compliance-technology questions only tangentially through its digital-innovation framing rather than through any confirmed RegTech deployment, supervisory-technology procurement, or active-defence tooling specific to the AML/CFT supervisory apparatus of Senegal. Honesty over coverage governs the treatment of this domain: rather than construct a compliance-technology narrative from adjacent findings, the monitor records the absence directly, consistent with the reduced word-floor convention applied to genuinely thin-signal domains this cycle. A domain that is exempt from the substantive-finding floor is not thereby exempt from scrutiny; it is flagged so that readers do not mistake silence for a confirmed absence of compliance-technology activity in the supervisory ecosystem of Senegal. #### Outlook This domain will be revisited as the supervisory institutions of Senegal, including CENTIF and the WAMU Banking Commission, potentially adopt or announce compliance-technology tooling in support of the Law 2024-08 implementation and the approaching ECOWAS beneficial-ownership register deadline; no such development was visible this cycle, and the monitor records this honestly as a coverage gap rather than inventing content to fill it. Future cycles will specifically probe for supervisory-technology procurement notices, transaction-monitoring system upgrades at Senegalese financial institutions, or CENTIF analytical-tooling announcements that would substantiate an active D6 finding rather than a structural placeholder. #### AML/CTF Regime Senegal's AML/CFT regime of record is Loi n deg 2024-08 du 14 fevrier 2024, which carries the full LBC/FT/PADM mandate — anti-money-laundering, counter-terrorist-financing, and counter-proliferation-financing obligations in a single instrument. The law extends reporting-entity status to virtual-asset service providers, bringing crypto-asset operators within the same obliged-entity perimeter as banks and payment companies, and places supervisory and financial-intelligence functions with CENTIF, the national financial intelligence unit. This is the structural fact against which the current evaluation cycle should be read: Senegal already operates a full reporting and supervisory architecture, rather than one still being built from a grey-listed baseline. Continue reading The procedural development this cycle is Senegal's progression through a third-round Mutual Evaluation under the Inter-Governmental Action Group against Money Laundering in West Africa. GIABA's own member-state material confirms that the process began on 9 January 2026, that an on-site visit took place between 10 and 28 August 2026, and that the evaluation is expected to continue through to May 2027. This follows the second-round Mutual Evaluation Report adopted by the GIABA Plenary in November 2018, with some aspects validated in May 2019 — meaning the jurisdiction has now gone through a full evaluation cycle since its last comprehensive assessment and is due a fresh rating across the FATF's effectiveness and technical-compliance measures. The architecture-over-incident reading here is that no single enforcement action or designation drives this cycle's record; the signal is structural and procedural. Senegal's standing as having exited the FATF grey list in October 2024 is the baseline the new evaluation will test. A grey-list exit achieved under one evaluation round does not itself guarantee the outcome of the next, and the third-round assessment — covering both the adequacy of the legal framework established by Loi n deg 2024-08 and its effectiveness in practice, including supervision of the newly captured virtual-asset-service-provider population — is the mechanism through which that question will be settled. Importantly, no T1 primary-instrument text for Loi n deg 2024-08 itself was retrieved this cycle; the regime description rests on secondary press reporting of CENTIF's own activity presentation, which is a gap in the sourcing available rather than a gap in the regime's existence. The three-pillar balance point worth surfacing explicitly is that counter-proliferation-financing sits inside the same 2024 law as the AML and CTF pillars, which is a more integrated structure than jurisdictions that legislate the three pillars separately or leave counter-proliferation-financing to subsidiary instruments. Whether CENTIF's supervisory capacity and resourcing are proportionate to this integrated mandate, particularly given the new virtual-asset-service-provider population it must now oversee, is not addressed in the material available this cycle and should be treated as an open question pending the Mutual Evaluation Report. #### Outlook The adoption of the third-round Mutual Evaluation Report by the GIABA Plenary is the event that will reset the baseline for Senegal's AML/CFT standing. As scheduled, the evaluation process runs to May 2027, with the report's substantive findings — on both technical compliance with the Loi n deg 2024-08 framework and its effectiveness in practice — to follow GIABA Plenary deliberation. Until that report is adopted, the standing description of Senegal's regime rests on the 2024 law and CENTIF's supervisory role as currently understood, with the caveat that primary-instrument confirmation of that law's specific provisions has not yet been obtained independently. The virtual-asset-service-provider obligations embedded in the 2024 law are worth continued attention, since any finding in the forthcoming evaluation that touches crypto-asset supervision would bear directly on how Senegal's integrity regime is read in the context of the broader regional digital-asset rulemaking still in preparation. BCEAO mandates use of the regional PI-SPI instant-payment platform for interoperable e-money transactions across UEMOA from 2 November 2026, with a revised fee schedule; Senegal hosts the largest national share of connected participants (43 of 175). Regulatory horizon Consultation 2027 · ±multi_year ### WAEMU crypto-asset regulation (C-CRYPTO committee) A dedicated WAEMU crypto-asset regulatory framework modelled on MiCA remains in preparation with no confirmed publication date. [Source](https://www.ecofinagency.com/news-finances/2407-57691-waemu-cryptoasset-regulation-remains-in-preparation-bceao-urges-caution) Consultation 2027 · ±multi_year ### WAEMU crypto-asset regulatory framework (C-CRYPTO) A future WAEMU framework is expected to establish authorisation, classification and prudential rules for crypto-assets; no timeline is set as of the governor's 22 July 2026 statement. [BCEAO / AMF-UMOA Source](https://www.bceao.int/sites/default/files/2026-04/Communique-sur-la-Conference-internationale-2026-sur-les-crypto-actifs.pdf) Consultation 2027-Q2 · ±year ### GIABA Third-Round Mutual Evaluation of Senegal Senegal's AML/CFT technical-compliance and effectiveness ratings will be reassessed under GIABA's third-round methodology, running January 2026-May 2027. [GIABA Source](https://lesoleil.sn/actualites/economie/le-senegal-entend-consolider-les-acquis-de-la-lutte-anti-blanchiment/) In Force Pending 2027-Q2 · ±half_year ### GIABA 3rd-round Mutual Evaluation of Senegal A new Mutual Evaluation Report and associated ratings for Senegal are expected to be adopted by GIABA Plenary following the August 2026 on-site visit. [Source](https://www.giaba.org/member-states/senegal.html) 4 dated · 2 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### Senegal's AML/CFT reporting perimeter, including virtual-asset-service-provider obligations under Loi n deg 2024-08, remains the operative standard while a GIABA mutual evaluation proceeds. The reporting obligations CENTIF administers, including those captured for virtual-asset service providers, remain the baseline to monitor against; no new trigger or threshold change was identified this cycle. 1 evidence refs Compliance ### Senegal is mid-way through a third-round GIABA Mutual Evaluation that will test the adequacy and effectiveness of its 2024 AML/CFT law. The outcome of the evaluation, expected by 2027 as scheduled, may surface gaps in the framework or its supervision that would affect the compliance posture obliged entities should adopt; no findings are yet public. 2 evidence refs Board ### Senegal's financial-crime standing remains stable while a formal evaluation of its regime is under way. No grey-list re-entry signal has emerged; the structural risk to monitor is the pending Mutual Evaluation Report outcome, expected as scheduled by 2027. 1 evidence refs Risk ### Senegal's risk direction is assessed as stable, with the GIABA evaluation as the structural factor to track. The evaluation covers both technical compliance and effectiveness, so its outcome could shift the jurisdiction's risk profile in either direction once published. 1 evidence refs Audit ### No primary-instrument text for Senegal's 2024 AML/CFT law has yet been independently retrieved this cycle. The current regime description rests on secondary press reporting rather than confirmed primary-source text, a gap recorded in the evidence base that bears on how confidently the regime's specific provisions can be documented. 1 evidence refs Scenario sketches ### AMLA transition and cross-border supervisory reach Illustrative only: as the European Union's Anti-Money Laundering Authority assumes direct and indirect supervision of selected cross-border obliged entities under the AMLA Regulation, alongside the directly-applicable AML Regulation and per-state transposition of the sixth AML Directive, the European supervisory perimeter could begin to extend its practical reach toward entities with correspondent or ownership links into non-EEA jurisdictions such as Senegal. This is an illustrative structural sketch of how supervisory architecture could evolve, not a description of any observed Senegal-specific development, and not a prediction of any particular outcome for Senegal's own evaluation. 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 stable No SN-nexus finding this cycle. T2 · EU AML Package / AMLA stable Not applicable to SN (non-EEA). T3 · FATF Grey List stable Senegal remains off the FATF grey list since October 2024; GIABA 3rd-round ME in progress. T4 · Beneficial-Ownership Register Status stable No SN-specific BO registry development identified this cycle. T5 · Crypto & Digital-Asset Integrity stable WAEMU crypto-asset regulation remains in preparation per BCEAO July 2026 statement. T6 · Sanctions Regime Divergence stable No SN-specific sanctions-divergence signal this cycle. Registers ### Enforcement actions - 23 Apr 2025 - 3 Jun 2025 - 26 Jun 2025 - 8 Jul 2024 - 13 Mar 2023 - 19 Sep 2023 - GIABA's 2024 Follow-Up Report re-rated Senegal on multiple FATF Recommendations (16, 19, 22, 23, among others) as Largely Compliant, crediting Act 2024-08 (transposing UEMOA Directive 01/2023) with resolving most previously identified deficiencies in customer due diligence, DNFBP obligations and targeted financial sanctions implementation. 23 Apr 2025 - Following the start of Sangomar oil production in mid-2024, Senegalese authorities intensified scrutiny of natural-resource contracts awarded to foreign investors to ensure alignment with national interests, triggering a tax dispute with Woodside over the project's fiscal terms. 3 Jun 2025 - UNODC ran a specialised capacity-building activity in Dakar (24-26 June 2025) for 22 Senegalese officials, including CENTIF staff, to strengthen strategies for investigating and prosecuting terrorism-organised crime financing convergence. 26 Jun 2025 ### Sanctions changes - 10 Jun 2025 - 25 Oct 2024 - The European Commission adopted Delegated Regulation (EU) 2025/1184, delisting Senegal (alongside Barbados, Gibraltar, Jamaica, Panama, the Philippines, Uganda and the UAE) from the EU's high-risk third-country AML/CFT list, following Senegal's FATF grey-list exit. 10 Jun 2025 - UK HM Treasury's High Risk Third Countries advisory notice is understood to have removed Senegal following FATF's October 2024 delisting, consistent with the UK's standard practice of mirroring FATF's Increased Monitoring list in its Money Laundering Regulations Schedule. 25 Oct 2024 ### Regulatory horizon (register) - ECOWAS Directive C/DIR.2/07/23 — central beneficial-ownership register deadline - GIABA Third-Round Mutual Evaluation of Senegal - BCEAO e-money ceiling increase takes effect - WAEMU crypto-asset regulation (C-CRYPTO committee) - WAEMU crypto-asset regulatory framework (C-CRYPTO) - BCEAO Instruction n°020 e-money ceiling increase and PI-SPI mandate take effect - GIABA 3rd-round Mutual Evaluation of Senegal - GIABA 5th-round mutual evaluation on-site assessment of Senegal - AMLR full application and AMLA assumption of EU high-risk-list methodology - Outstanding secondary legislation to close residual Act 2024-08 gaps ### Active schemes - [HIGH] Offshore-layered extractive concession structuring via PEP ties - Sahel gold-trafficking corridor through Kedougou artisanal mines - [HIGH] Senegal as recruitment and terrorism-financing transit outpost for Sahel jihadism - Cash and informal-economy laundering vulnerability via weak DNFBP oversight Sources - [Register of Commission Documents - C(2024)8662](https://ec.europa.eu/transparency/documents-register/detail?lang=en) - [https://www.fatf-gafi.org/en/countries/detail/Senegal.html](https://www.fatf-gafi.org/en/countries/detail/Senegal.html) - [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2024.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2024.html) - [https://lesoleil.sn/actualites/economie/le-senegal-entend-consolider-les-acquis-de-la-lutte-anti-blanchiment/](https://lesoleil.sn/actualites/economie/le-senegal-entend-consolider-les-acquis-de-la-lutte-anti-blanchiment/) - [https://senego.com/blanchiment-au-senegal-la-centif-enregistre-866-declarations-de-soupcon-en-2025_1960473.html](https://senego.com/blanchiment-au-senegal-la-centif-enregistre-866-declarations-de-soupcon-en-2025_1960473.html) - [https://www.pulse.sn/article/senegal-les-chiffres-alarmants-du-blanchiment-dargent-rapport-centif-2026051308504180438](https://www.pulse.sn/article/senegal-les-chiffres-alarmants-du-blanchiment-dargent-rapport-centif-2026051308504180438) - [https://fr.allafrica.com/stories/202501130660.html](https://fr.allafrica.com/stories/202501130660.html) - [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.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.financialafrik.com/2026/10/09/umoa-la-bceao-double-le-plafond-des-avoirs-en-monnaie-electronique-a-4-millions-de-fcfa/](https://www.financialafrik.com/2026/10/09/umoa-la-bceao-double-le-plafond-des-avoirs-en-monnaie-electronique-a-4-millions-de-fcfa/) - [https://fr.allafrica.com/stories/202610100078.html](https://fr.allafrica.com/stories/202610100078.html) - [https://www.fatf-gafi.org/en/countries/detail/Angola.html](https://www.fatf-gafi.org/en/countries/detail/Angola.html) - [https://site.centif.sn/fr/evgiaba](https://site.centif.sn/fr/evgiaba) - [https://launchbaseafrica.com/2026/10/01/fintech-unicorn-wave-caves-to-regulators-as-bceao-refuses-to-blink-on-west-africas-payment-deadline/](https://launchbaseafrica.com/2026/10/01/fintech-unicorn-wave-caves-to-regulators-as-bceao-refuses-to-blink-on-west-africas-payment-deadline/) - [https://www.bceao.int/sites/default/files/2026-04/Communique-sur-la-Conference-internationale-2026-sur-les-crypto-actifs.pdf](https://www.bceao.int/sites/default/files/2026-04/Communique-sur-la-Conference-internationale-2026-sur-les-crypto-actifs.pdf) - [GIABA](https://www.giaba.org/member-states/senegal.html) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2024.html) - [European Commission](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [GIABA/FATF](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/GIABA-Senegal-FUR-2024.pdf.coredownload.pdf) - [CENTIF Sénégal](https://www.centif.sn/asset/attachements/rapports/Rapport_activite_2024.pdf) - [Vie Publique Sénégal](https://www.vie-publique.sn/documents/11284/decret-2025-1354-registre-beneficiaires-effectifs-2025) - [BCEAO](https://www.bceao.int/fr/communique-presse/transactions-de-monnaie-electronique-entre-personnes-physiques-par-0) - [Sanctions Lawyers (aggregator)](https://sanctionslawyers.net/blog-en/fatf-grey-list-countries-2026/) - [NotreAfrik](https://notreafrik.com/tresor-ivoirien-pi-spi/) - [https://www.centif.sn/fr/evgiaba](https://www.centif.sn/fr/evgiaba) - [https://fr.allafrica.com/stories/202608310705.html](https://fr.allafrica.com/stories/202608310705.html) - [https://www.business-humanrights.org/en/latest-news/s%C3%A9n%C3%A9gal-transparence-dans-les-industries-extractives-le-registre-des-b%C3%A9n%C3%A9ficiaires-effectifs-des-entreprises-du-secteur-d%C3%A9sormais-accessible-au-grand-public/](https://www.business-humanrights.org/en/latest-news/s%C3%A9n%C3%A9gal-transparence-dans-les-industries-extractives-le-registre-des-b%C3%A9n%C3%A9ficiaires-effectifs-des-entreprises-du-secteur-d%C3%A9sormais-accessible-au-grand-public/) - [https://www.financialafrik.com/2026/10/12/le-senegal-distingue-pour-ses-performances-en-matiere-de-transparence-extractive/](https://www.financialafrik.com/2026/10/12/le-senegal-distingue-pour-ses-performances-en-matiere-de-transparence-extractive/) - [https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/GIABA-Senegal-FUR-2024.pdf.coredownload.pdf](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/GIABA-Senegal-FUR-2024.pdf.coredownload.pdf) - [https://wiki.private.law/en/fatf](https://wiki.private.law/en/fatf) - [Le Soleil](https://lesoleil.sn/actualites/economie/le-senegal-entend-consolider-les-acquis-de-la-lutte-anti-blanchiment/) - [Ecofin Agency](https://www.ecofinagency.com/news-finances/2407-57691-waemu-cryptoasset-regulation-remains-in-preparation-bceao-urges-caution) - [Senegal](https://www.fatf-gafi.org/en/countries/detail/Senegal.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.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) - [South Africa](https://www.fatf-gafi.org/en/countries/detail/South-Africa.html) - [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) - [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) - [Joint African Development Bank - Financial Action Task Force webinar: Exiting the FATF Grey List – Success Stories and Pathways to Sustainable Compliance](https://www.fatf-gafi.org/en/publications/Fatfgeneral/joint-AfDB-FATF-webinar.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [Nigeria](https://www.fatf-gafi.org/en/countries/detail/Nigeria.html) - [Jurisdictions under Increased Monitoring - 24 October 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html) - [Senegal's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-senegal-feb-2022.html) - [Senegal's measures to combat money laundering and the financing of terrorism and proliferation](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-senegal-2018.html) - [Anti-money laundering and counter-terrorist financing measures Senegal](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/GIABA-Mutual-Evaluation-Senegal-2018.pdf.coredownload.inline.pdf) - [Outcomes Joint FATF-MONEYVAL Plenary, 12-13 June 2025](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-FATF-MONEYVAL-plenary-june-2025.html) - [Mutual Evaluation of Senegal](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofsenegal.html) - [GIABA Follow-Up Report Senegal - 2024](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/GIABA-Senegal-FUR-2024.pdf.coredownload.pdf) - [News](https://www.fatf-gafi.org/en/the-fatf/news.html) - [Angola](https://www.fatf-gafi.org/en/countries/detail/Angola.html) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [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) - [Anti-Money Laundering and Terrorist Financing Directive 4 - Finance](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/anti-money-laundering-and-terrorist-financing-directive-4_en) - [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html) - [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) - [Senegal - H.E. Mr. Macky Sall, President | Africa Renewal Online](https://www.un.org/africarenewal/africaga2015/senegal-he-mr-macky-sall-president) - [Senegal’s Former President Sall Denies Understating State Debt - Bloomberg](https://www.bloomberg.com/news/articles/2024-10-15/senegal-s-former-president-sall-denies-understating-state-debt) - [Intensifying the fight against corruption and money laundering in Africa](https://www.un.org/osaa/sites/www.un.org.osaa/files/intensifying_the_fight_against_corruption_and_money_laundering_0.pdf) - [UK-Senegal Political Dialogue, 2023: joint communiqué - GOV.UK](https://www.gov.uk/government/publications/uk-senegal-political-dialogue-2023-joint-communique/uk-senegal-political-dialogue-2023-joint-communique) - [Study: Intensifying the fight against corruption and money laundering in Africa | Office of the Special Adviser on Africa](https://www.un.org/osaa/en/reports-and-publications/study-intensifying-fight-against-corruption-and-money-laundering-africa) - [Illicit Financial Flows fuelling conflicts and embezzling Africa’s future? | Office of the Special Adviser on Africa](https://www.un.org/osaa/news/illicit-financial-flows-fuelling-conflicts-and-embezzling-africa%E2%80%99s-future) - [Home | Africa Renewal](https://www.un.org/africarenewal/illicit-financial-flows) - [CASEBOOK ON Money Laundering and Proceeds of Crime](https://www.unodc.org/documents/southernafrica/Publications/TransnationalOrganisedCrime/case_book_final_17032021.pdf) - [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) - [GOLD TRAFFICKING IN THE SAHEL](https://www.unodc.org/documents/data-and-analysis/tocta_sahel/TOCTA_Sahel_Gold_v5.pdf) - [Terrorist Financing in West Africa](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Tf-west-africa.html) - [fatf REPORT TERRORIST FINANCING IN WEST AFRICA October 2013](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/TF-in-West-Africa.pdf.coredownload.inline.pdf) - [2025 UNODC and Senegal Continue Their Efforts in Preventing and Countering the Nexus Between Terrorism and Organized Crime and Strengthening Inter-Agency Cooperation](https://www.unodc.org/unodc/en/terrorism/latest-news/2025-unodc-and-senegal-continue-their-efforts-in-preventing-and-countering-the-nexus-between-terrorism-and-organized-crime-and-strengthening-inter-agency-cooperation.html) - [FATF report highlights evolving terrorist financing risks and warns of gaps in global understanding of the threats](https://www.fatf-gafi.org/en/publications/Methodsandtrends/comprehensive-update-terrorist-financing-risks-2025.html) - [TERRORIST FINANCING IN WEST AND CENTRAL AFRICA October 2016](https://www.fatf-gafi.org/media/fatf/documents/reports/Terrorist-Financing-West-Central-Africa.pdf) - [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) - [Africa Gold Advisory](https://ofac.treasury.gov/system/files/2023-06/africa_gold_advisory_06272023.pdf) - [2025 Monitoring Report February 2025 Senegal](https://www.un.org/development/desa/dpad/wp-content/uploads/sites/45/CDP-PL-2025-SEN.pdf) - [Country Profile: Senegal](https://www.unodc.org/corruption/en/country-profiles/data/SEN.html) - [Senegal Moves to Ease Voting Rules That Barred Sonko From Race - Bloomberg](https://www.bloomberg.com/news/articles/2026-04-29/senegal-moves-to-ease-voting-rules-that-barred-sonko-from-race) - [1 Financial Crimes Enforcement Network (FinCEN)](https://www.fincen.gov/system/files/2026-05/FinCEN-Year-in-Review-2025.pdf) - [Senegal Opposition Leader Sonko Arrested, Sparking Unrest - Bloomberg](https://www.bloomberg.com/news/articles/2023-07-28/senegal-opposition-leader-sonko-arrested-sparking-unrest) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [South Africa Flags Crypto, Stablecoins as New Financial Risk - Bloomberg](https://www.bloomberg.com/news/articles/2025-11-25/south-africa-central-bank-flags-crypto-stablecoins-as-new-risk) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [Sub-Saharan Africa Crypto Adoption Trends and Analysis](https://www.chainalysis.com/blog/africa-cryptocurrency-adoption/) - [Sub-Saharan Africa Shows Strong Crypto Retail Activity](https://www.chainalysis.com/blog/subsaharan-africa-crypto-adoption-2025/) - [Watch Crypto Regulation and Proliferation in Africa - Bloomberg](https://www.bloomberg.com/news/videos/2025-07-06/crypto-regulation-and-proliferation-in-africa) - [What is crypto AML compliance?](https://www.elliptic.co/blockchain-basics/what-is-crypto-aml-compliance) - [Digital Assets in Digital Finance Regulatory Standards and Law](https://uncitral.un.org/sites/uncitral.un.org/files/media-documents/uncitral/en/castellano_updated.pdf) - [Woodside Files for Arbitration in Senegal Over Sangomar Oil Tax - Bloomberg](https://www.bloomberg.com/news/articles/2025-06-03/woodside-files-for-arbitration-in-senegal-over-sangomar-oil-tax) - [A gold rush trap: How smuggled migrants end up exploited in African mines on their way to the Mediterranean](https://www.unodc.org/unodc/en/frontpage/2024/January/a-gold-rush-trap_-how-smuggled-migrants-end-up-exploited-in-african-mines-on-their-way-to-the-mediterranean.html) - [Senegal’s Offshore Oil Reserves a Pricey Pawn in Covert Deal | OCCRP](https://www.occrp.org/en/investigation/senegals-offshore-oil-reserves-a-pricey-pawn-in-covert-deal) - [India’s ONGC Is Said to Eye Woodside Stake in Senegal Oil Field - Bloomberg](https://www.bloomberg.com/news/articles/2021-09-08/india-s-ongc-is-said-to-eye-woodside-stake-in-senegal-oil-field) - [Senegal’s Petrosen Plans Its Own $100 Million Onshore Oil Search - Bloomberg](https://www.bloomberg.com/news/articles/2026-02-10/senegal-s-petrosen-plans-its-own-100-million-onshore-oil-search) - [Senegal - Economic Analysis - the United Nations](https://policy.desa.un.org/sites/default/files/2025-06/cdp-pl-2025-sen.pdf) - [Global Witness raises question about new DRC gold refinery | Global Witness](https://globalwitness.org/en/press-releases/new-gold-refinery-in-drc-links-a-senior-employee-of-erik-princes-security-firm-to-a-close-associate-of-ex-president-joseph-kabila-and-a-reported-gold-smuggler-global-witness-reveals/) - [REPUBLIC OF SENEGAL One People – One Goal – One Faith MINUTES](https://www.occrp.org/documents/senegals-offshore-oil-reserves-a-pricey-pawn-in-covert-deal/OFNAC-SALL-2.pdf) - [REPUBLIC OF SENE- GAL One People – One Goal – One Faith](https://www.occrp.org/documents/senegals-offshore-oil-reserves-a-pricey-pawn-in-covert-deal/FayeInterview.pdf) - [Occrp](https://www.occrp.org/documents/senegals-offshore-oil-reserves-a-pricey-pawn-in-covert-deal/MackyApproval.pdf) - [republic of senegal](https://admin.occrp.org/documents/senegals-offshore-oil-reserves-a-pricey-pawn-in-covert-deal/Tullow-Testimony.pdf) - [REPUBLIC OF SENEGAL INQUIRIES AND INVESTIGA](https://cdn.occrp.org/projects/documents/website-documents-folder/senegals-offshore-oil-reserves-a-pricey-pawn-in-covert-deal/MbodjiInterview2.pdf) - [Frank Timis | OCCRP](https://www.occrp.org/en/people/frank-timis/page/1) - [Global Witness calls on UK and US to investigate BP and "City bad boy" Frank Timis | Global Witness](https://globalwitness.org/en/press-releases/global-witness-calls-on-uk-and-us-to-investigate-bp-and-city-bad-boy-frank-timis/) - [REPUBLIC OF SENEGAL One People](https://cdn.occrp.org/projects/documents/website-documents-folder/senegals-offshore-oil-reserves-a-pricey-pawn-in-covert-deal/MbodjiInterview.pdf) - [British Petroleum | OCCRP](https://www.occrp.org/en/organizations/british-petroleum) - [Jurisdictions under Increased Monitoring - June 2024](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2024.html) - [Guidance on Beneficial Ownership of Legal Persons](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.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) - [Guidance on Beneficial Ownership and Transparency of Legal Arrangements](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.html) - [Jurisdictions under Increased Monitoring - 24 February 2023](https://www.fatf-gafi.org/en/publications/high-risk-and-other-monitored-jurisdictions/documents/increased-monitoring-february-2023.html) - [Mutual Evaluation of Senegal](https://www.fatf-gafi.org/en/countries/s-t/senegal/documents/mutualevaluationofsenegal.html) - [Quick guide on assessing the Money Laundering risks of corruption](https://www.fatf-gafi.org/en/publications/Methodsandtrends/quick-guide-on-assessing-ML-risks-of-corruption.html) - [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-4) - [FATF launches National Risk Assessment toolkit to help countries identify greatest money laundering risks](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-launches-National-Risk-Assessment-toolkit-to-help-countries-identify-greatest-money-laundering-risks.html) - [UEMOA (West African Economic and Monetary Union) - Mobility and Transport](https://transport.ec.europa.eu/transport-modes/air/international-aviation/status-aviation-relations-country/uemoa-west-african-economic-and-monetary-union_en) - [Senegal - International Partnerships - European Commission](https://international-partnerships.ec.europa.eu/countries/senegal_en?prefLang=ro) - [Erasmus+ for higher education in Senegal What is Erasmus+ ?](https://erasmus-networks.ec.europa.eu/system/files/2025-07/senegal_erasmusplus_2024.pdf) - [Senegal](https://webgate.ec.europa.eu/isdb_results/factsheets/country/overview_senegal_en.pdf) - [European Peace Facility: Council adopts assistance measure in support of Senegal - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/07/08/european-peace-facility-council-adopts-assistance-measure-in-support-of-senegal/) - [Senegal: Statement by the High Representative on behalf of the European Union - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2024/02/09/senegal-declaration-du-haut-representant-au-nom-de-l-union-europeenne/) - [Register of Commission Documents - C(2024)8662](https://ec.europa.eu/transparency/documents-register/detail?lang=en) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Senegal.html) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2024.html) - [GIABA / FATF Global Network](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/GIABA-Senegal-FUR-2024.pdf.coredownload.pdf) - [GIABA / FATF](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/GIABA-Mutual-Evaluation-Senegal-2018.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 (UK)](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/hm-treasury-advisory-notice-high-risk-third-countries) - [OCCRP](https://www.occrp.org/en/investigation/senegals-offshore-oil-reserves-a-pricey-pawn-in-covert-deal) - [Global Witness](https://globalwitness.org/en/press-releases/global-witness-calls-on-uk-and-us-to-investigate-bp-and-city-bad-boy-frank-timis/) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-06-03/woodside-files-for-arbitration-in-senegal-over-sangomar-oil-tax) - [Bloomberg](https://www.bloomberg.com/news/articles/2024-10-15/senegal-s-former-president-sall-denies-understating-state-debt) - [UNODC](https://www.unodc.org/unodc/en/frontpage/2024/January/a-gold-rush-trap_-how-smuggled-migrants-end-up-exploited-in-african-mines-on-their-way-to-the-mediterranean.html) - [UNODC](https://www.unodc.org/unodc/en/terrorism/latest-news/2025-unodc-and-senegal-continue-their-efforts-in-preventing-and-countering-the-nexus-between-terrorism-and-organized-crime-and-strengthening-inter-agency-cooperation.html) - [Chainalysis](https://www.chainalysis.com/blog/subsaharan-africa-crypto-adoption-2025/) Coverage gaps fim-int-2026-07-05-G001: Exact date of UK HM Treasury remova… fim-int-2026-07-05-G001: Exact date of UK HM Treasury removal of Senegal from the High Risk Third Countries advisory list is not independently confirmed; a directly dated post-October-2024 gov.uk publication would resolve this. [resolved] fim-int-2026-07-05-G002: A Senegal or UEMOA-specific virtual… fim-int-2026-07-05-G002: A Senegal or UEMOA-specific virtual-asset-service-provider regulatory analysis, rather than regional Sub-Saharan Africa aggregate data, would improve confidence on the D5 regulatory-gap finding. [resolved] fim-int-2026-07-05-G003: An independent ICIJ-style beneficia… fim-int-2026-07-05-G003: An independent ICIJ-style beneficial-ownership register effectiveness audit specific to Senegal would clarify the gap between formal BO record-keeping and operational transparency in the extractive sector. [resolved] fim-int-2026-07-05-G004: Direct evidence confirming or rulin… fim-int-2026-07-05-G004: Direct evidence confirming or ruling out Wagner Group or Africa Corps-linked gold or logistics spillover through Dakar port infrastructure would resolve the current absence-of-evidence status on tracker T1. [resolved] fim-int-2026-07-05-G005: No RegTech, AI/ML transaction-monit… fim-int-2026-07-05-G005: No RegTech, AI/ML transaction-monitoring, or perpetual-KYC sourcing was located for Senegal or CENTIF this baseline; targeted research on domestic FIU technology adoption would populate domain D6. [resolved] fim-int-2026-08-05-G001: No Tier-1 primary source was locate… fim-int-2026-08-05-G001: No Tier-1 primary source was located for the ECOWAS BO-register directive text itself this cycle. [resolved] fim-int-2026-08-05-G002: No TBML-corridor-specific findings … fim-int-2026-08-05-G002: No TBML-corridor-specific findings for Senegal surfaced this cycle despite active search. [resolved] fim-int-2026-08-05-G003: D4 (conflict finance) and D6 (compl… fim-int-2026-08-05-G003: D4 (conflict finance) and D6 (compliance technology) coverage for Senegal remained thin this cycle. [resolved] fim-int-2026-08-05-G004: No Senegal-specific enforcement act… fim-int-2026-08-05-G004: No Senegal-specific enforcement action was confirmed in the WAMU Banking Commission's most recent (March 2026) session; only Niger- and Burkina Faso-based licence withdrawals were named. [resolved] fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No T1/T2-sourced D1 sanctions finding specific to Senegal was located this cycle. [resolved] fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): No jurisdiction-specific D3 enabler-facilitator finding beyond the general shell-company pattern already captured under D2/D7 was located this cycle. [resolved] fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', 'value': 'D4'}): No D4 conflict-finance or extractive-industry integrity signal for Senegal was located this cycle. [resolved] fim-int-2026-09-05-G004 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G004 ({'scheme': 'financial_integrity', 'value': 'D7'}): No primary CENTIF-hosted T1 document was retrieved directly this cycle; STR figures rest on two corroborating T3 press sources. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D4'}): No Senegal-specific D4 (conflict finance) finding was located this cycle. [resolved] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): No Senegal-specific beneficial-ownership registry effectiveness data was located this cycle; T4 tracker carried forward uncertain. [resolved] fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): No primary BCEAO instrument PDF for Instruction n°020 was independently retrieved; confidence rests on convergent secondary press reporting. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No Senegal-specific D1 Sanctions designation activity located this cycle. [resolved] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): No Senegal-specific D3 Enabler Jurisdictions finding located this cycle. [resolved] fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', 'value': 'D4'}): No Senegal-specific D4 Conflict Finance finding located this cycle. [resolved] fim-int-2026-10-18-G004: Tier D watch jurisdictions (KH/LA/M… fim-int-2026-10-18-G004: Tier D watch jurisdictions (KH/LA/MX/CO) were not independently searched this cycle given the single-jurisdiction scope of this dispatch. [resolved] fim-int-2026-10-25-G001: No independent search of UN Panel o… fim-int-2026-10-25-G001: No independent search of UN Panel of Experts (Yemen)/OFAC/OFSI Houthi-designation nexus to Senegal was run this cycle due to budget prioritisation; coverage gap not confirmed absence. [open] fim-int-2026-10-25-G002: Tier-D jurisdictions (Cambodia, Lao… fim-int-2026-10-25-G002: Tier-D jurisdictions (Cambodia, Laos, Mexico, Colombia) were not actively searched this cycle for any Senegal-linked nexus. [open] fim-int-2026-10-25-G003: D5 Crypto/Digital Assets coverage f… fim-int-2026-10-25-G003: D5 Crypto/Digital Assets coverage for Senegal was thin this cycle beyond the BCEAO C-CRYPTO standing position already carried in crypto's own sub-envelope; no FIM-native crypto-AML finding was sourced. [open] fim-int-2026-10-25-G004: D3 Enabler Jurisdictions and D4 Con… fim-int-2026-10-25-G004: D3 Enabler Jurisdictions and D4 Conflict Finance produced no Senegal-specific finding this cycle; absence recorded as a coverage gap rather than a confirmed null given the research budget allocation to D2/D7. [open] fim-int-2026-11-01-G001: No SN-specific finding in D1 (Sanct… fim-int-2026-11-01-G001: No SN-specific finding in D1 (Sanctions), D2 (Beneficial Ownership), D3 (Enabler Jurisdictions), D4 (Conflict Finance), D5 (Crypto/Digital Assets), D6 (Compliance Technology), D8 (Commercial Activity) in the window since 2026-10-25. [open] fim-int-2026-11-01-G002: min_t1_per_instrument_met and juris… fim-int-2026-11-01-G002: min_t1_per_instrument_met and jurisdiction_source_floor_met are both false per Station-1 publication_gate; no T1 primary instrument text was retrieved for Loi n°2024-08 itself this cycle. [open] FIM-GAP-001 (D3): Despite legislative modernisation via Act … FIM-GAP-001 (D3): Despite legislative modernisation via Act 2024-08, Senegal's practical capacity to detect AML/CFT violations by DNFBPs and impose effective, proportionate, dissuasive sanctions remains a recurring theme across successive FATF/GIABA statements from 2023 through the 2024 Follow-Up Report. FIM-GAP-002 (D2): The Petro-Tim/Timis Corp offshore oil-conc… FIM-GAP-002 (D2): The Petro-Tim/Timis Corp offshore oil-concession affair, involving Cayman/BVI shell structures and a presidential-family PEP nexus, produced OFNAC investigative interviews but no confirmed prosecution, asset recovery, or beneficial-ownership remediation; the 2025 Woodside Sangomar tax dispute shows continued opacity friction in the same extractive sector. FIM-GAP-003 (D5): No dedicated Senegalese or UEMOA-wide virt… FIM-GAP-003 (D5): No dedicated Senegalese or UEMOA-wide virtual asset service provider licensing/AML regime was identified in available primary or investigative sourcing; regional crypto-market analyses (Chainalysis) address Sub-Saharan Africa broadly (Nigeria, South Africa as leaders) without Senegal-specific regulatory detail, indicating both a substantive regulatory gap and a sourcing-thinness constraint on this baseline's D5 coverage for Senegal specifically. FIM-GAP-004 (D3): An audit commissioned by the incoming Sonk… FIM-GAP-004 (D3): An audit commissioned by the incoming Sonko government found Senegal's public debt-to-GDP ratio under former President Macky Sall averaged 76.3% (versus 65.9% reported) and a budget deficit near double the previously stated figure, triggering a sovereign credit downgrade and suspension of Senegal's IMF Extended Credit Facility programme. FIM-GAP-005 (D3): Senegalese lawmakers approved amendments i… FIM-GAP-005 (D3): Senegalese lawmakers approved amendments in April 2026 narrowing the range of criminal convictions that disqualify presidential candidates, limiting ineligibility largely to economic crimes such as corruption and embezzlement, in a context where Prime Minister Sonko had previously faced multiple charges including economic-crime-adjacent counts. FIM-GAP-006 (D2): This baseline could not independently conf… FIM-GAP-006 (D2): This baseline could not independently confirm the exact date UK HM Treasury removed Senegal from its High Risk Third Countries advisory list; the only retrieved gov.uk version predates the October 2024 FATF delisting. The SANC-002 entry's date is therefore an inference from standard UK alignment practice, not a directly sourced confirmation. ## Evidence #### Confidence-tiered claims Per-client e-money balance ceiling doubled from FCFA 2m to FCFA 4m; monthly cumulative top-up ceiling raised from FCFA 10m to FCFA 15m, effective 2 November 2026. [[Source 1]](#sec-sources) Probable · 1 source Senegal's AML Law n°2024-08 of 14 February 2024 explicitly extends reporting-entity obligations to 'Prestataires de services d'actifs virtuels (PSAV)'. [[Source 1]](#sec-sources) Probable · 1 source Senegal remains off the FATF increased-monitoring list, having exited in October 2024. [[Source 1]](#sec-sources) Probable · 1 source GIABA on-site assessor visit for Senegal's third-round mutual evaluation ran 10-28 August 2026. [[Source 1]](#sec-sources) Probable · 1 source WAEMU crypto-asset regulation (MiCA-inspired) drafted by BCEAO's C-CRYPTO committee remains 'in preparation' with no confirmed publication date, per BCEAO's most recent (July 2026) statement. [[Source 1]](#sec-sources) Probable · 1 source 175 participants authorised to offer PI-SPI services across WAEMU as of 30 September 2026 list; Senegal is largest single-country cohort. [[Source 1]](#sec-sources) Probable · 1 source Loi n°2024-08 du 14 février 2024 (LBC/FT/PADM), with CENTIF as the designated FIU and GIABA's 6th Enhanced Follow-Up Report (Sept 2026) confirming a solid legislative framework. [[Source 1]](#sec-sources) Probable · 1 source Removed from FATF grey list at 25 October 2024 plenary; remains off the list. [[Source 1]](#sec-sources) Probable · 1 source Removed from EU list of high-risk third countries on 10 June 2025; remains off that list. [[Source 1]](#sec-sources) Probable · 1 source Mandatory use of PI-SPI instant-payment platform for interoperable e-money transactions across UEMOA from 2 November 2026, with revised fee schedule; Senegal hosts the largest national share of connected participants (43 of 175). [[Source 1]](#sec-sources) Probable · 1 source Per secondary reporting, raises e-money wallet ceiling to XOF 4,000,000 per client/issuer and monthly top-up cap to XOF 15,000,000, effective 2 November 2026. [[Source 1]](#sec-sources) Probable · 1 source 2024 activity report notes ongoing staff training needs on complex financial-data analysis. [[Source 1]](#sec-sources) Probable · 1 source Regional crypto-asset regulatory framework remains in preparation, with no announced timeline as of Governor Kassi Brou's 22 July 2026 statement. [[Source 1]](#sec-sources) Probable · 1 source Virtual-asset service providers explicitly designated as AML/CFT reporting entities; CENTIF is the supervising FIU [[Source 1]](#sec-sources) Probable · 1 source Senegal, 3rd round, begun 9 January 2026, on-site visit 10-28 August 2026, outcome expected ~May 2027 [[Source 1]](#sec-sources) Probable · 1 source No longer subject to FATF increased monitoring (exited 25 October 2024) [[Source 1]](#sec-sources) Probable · 1 source Opened to unconditional public access under Décret n°2025-1354 du 27 août 2025; cited when Senegal won the EITI Chair's Award 2026 (8 October 2026, 89/100 validation score) [[Source 1]](#sec-sources) Probable · 1 source Removed from EU high-risk third-country list via Delegated Regulation 2025/1184, in force 5 August 2025 [[Source 1]](#sec-sources) Probable · 1 source CENTIF [[Source 1]](#sec-sources) Probable · 1 source GIABA 3rd-round Mutual Evaluation (begun 2026-01-09, on-site visit 2026-08-10 to 2026-08-28) [[Source 1]](#sec-sources) Probable · 1 source Loi n°2024-08 du 14 février 2024, extending obliged-entity scope to virtual-asset service providers (PSAV); CENTIF as FIU [[Source 1]](#sec-sources) Probable · 1 source On-site evaluation mission conducted 10-28 August 2026; plenary adoption targeted May 2027 [[Source 1]](#sec-sources) Probable · 1 source