This document contains a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Senegal from May 2018. It finds that Senegal has achieved low effectiveness in 11 of its core objectives to combat money laundering and terrorist financing. On technical compliance, it rates Senegal as partially compliant or non-compliant on 25 of the 40 FATF recommendations. Overall, the report identifies several priority areas for Senegal to strengthen its anti-money laundering and counter-terrorist financing regime.

1. Anti-money laundering and counter-terrorist financing measures in Senegal – Mutual Evaluation Report – May 2018 1
Anti-money laundering and counter-
terrorist financing (AML/CFT) measures
in Senegal
Fourth Round Mutual Evaluation
Key findings, ratings and priority actions
May 2018
http://www.fatf-gafi.org/publications/mutualevaluations/documents/mer-burkina-faso-2019.html

2. Anti-money laundering and counter-terrorist financing measures in Senegal – Mutual Evaluation Report – May 2018
Ratings – Effectiveness (1/3)
2
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which
Senegal has
achieved this
objective
1. ML and TF risks are understood and, where appropriate,
actions co-ordinated domestically to combat ML and TF
Low
2. International co-operation delivers appropriate information,
financial intelligence, and evidence, and facilitates action
against criminals and their assets
Low
3. Supervisors appropriately supervise, monitor and regulate
financial institutions and designated non-financial
businesses and professions (DNFBPs) for compliance with
AML/CFT requirements commensurate with their risks.
Low
4. Financial institutions and DNFBPs adequately apply AML/CFT
preventive measures commensurate with their risks, and
report suspicious transactions.
Low

3. Anti-money laundering and counter-terrorist financing measures in Senegal – Mutual Evaluation Report – May 2018 3
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which
Senegal has
achieved this
objective
5. Legal persons and arrangements are prevented from misuse
for money laundering or terrorist financing, and information
on their beneficial ownership is available to competent
authorities without impediments
Low
6. Financial intelligence and all other relevant information are
appropriately used by competent authorities for money
laundering and terrorist financing investigations.
Moderate
7. Money laundering offences and activities are investigated
and offenders are prosecuted and subject to effective,
proportionate and dissuasive sanctions
Low
8. Proceeds and instrumentalities of crime are confiscated. Low
Ratings – Effectiveness (2/3)

4. Anti-money laundering and counter-terrorist financing measures in Senegal – Mutual Evaluation Report – May 2018 4
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which
Senegal has
achieved this
objective
9. Terrorist financing offences and activities are investigated
and persons who finance terrorism are prosecuted and
subject to effective, proportionate and dissuasive sanctions.
Low
10. Terrorists, terrorist organisations and terrorist financiers are
prevented from raising, moving and using funds, and from
abusing the non-profit sector.
Low
11. Persons and entities involved in the proliferation of weapons
of mass destruction are prevented from raising, moving and
using funds, consistent with the relevant United Nations
Security Council Resolutions.
Low
Ratings – Effectiveness (3/3)

5. Anti-money laundering and counter-terrorist financing measures in Senegal – Mutual Evaluation Report – May 2018 5
Ratings – Effectiveness
00 1
10
High
Substantial
Moderate
Low

6. 6
Ratings – technical compliance
(1/5)
September
2016
AML/CFT POLICIES AND COORDINATION
1. Assessing risks & applying a risk-based approach Par Pa ParPar Partially Compliant
2. National cooperation and coordination LargLarLarLar Largely Compliant
MONEY LAUNDERING AND CONFISCATION
3. Money laundering offence LargLarLarLar Largely Compliant
4. Confiscation and provisional measures Par Pa ParPar Partially Compliant
TERRORIST FINANCING AND FINANCING OF PROLIFERATION
5. Terrorist financing offence Par Pa ParPar Partially Compliant
6. Targeted financial sanctions related to terrorism & terrorist
financing NonNo NonNon Non Compliant
7. Targeted financial sanctions related to proliferation NonNonNonNon Non Compliant
8. Non-profit organisations Par ParParPar Partially Compliant

7. 7
Ratings – technical compliance
(2/5)
September
2016
PREVENTIVE MEASURES
9. Financial institution secrecy laws ComCo ComCom Compliant
Customer due diligence and record keeping
10. Customer due diligence Par Pa ParPar Partially Compliant
11. Record keeping LargLarLarLar Largely Compliant
Additional measures for specific customers and activities
12. Politically exposed persons NonNo NonNon Non Compliant
13. Correspondent banking NonNo NonNon Non Compliant
14. Money or value transfer services LargLarLarLar Largely Compliant
15. New technologies Par ParParPar Partially Compliant
16. Wire transfers Par ParParPar Partially Compliant

8. 8
Ratings – technical compliance
(3/5)
September
2016
PREVENTIVE MEASURES (continued)
Reliance, Controls and Financial Groups
17. Reliance on third parties Par Pa ParPar Partially Compliant
18. Internal controls and foreign branches and subsidiaries Par Pa ParPar Partially Compliant
19. Higher-risk countries NonNo NonNon Non Compliant
Reporting of suspicious transactions
20. Reporting of suspicious transactions ComCo ComCom Compliant
21. Tipping-off and confidentiality ComCo ComCom Compliant
Designated non-financial Businesses and Professions (DNFBPs)
22. DNFBPs: Customer due diligence Par Pa ParPar Partially Compliant
23. DNFBPs: Other measures Par Pa ParPar Partially Compliant
TRANSPARENCY AND BENEFICIAL OWNERSHIP OF LEGAL
PERSONS AND ARRANGEMENTS
24. Transparency and beneficial ownership of legal persons Par Pa ParPar Partially Compliant
25. Transparency and beneficial ownership of legal arrangements NonNo NonNon Non Compliant

9. 9
Ratings – technical compliance
(4/5)
September
2016
POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES
AND OTHER INSTITUTIONAL MEASURES
Regulation and Supervision
26. Regulation and supervision of financial institutions Par Pa ParPar Partially Compliant
27. Powers of supervisors ComCo ComCom Compliant
28. Regulation and supervision of DNFBPs NonNo NonNon Non Compliant
Operational and Law Enforcement
29. Financial intelligence units LargLarLarLar Largely Compliant
30. Responsibilities of law enforcement and investigative
authorities LargLarLarLar Largely Compliant
31. Powers of law enforcement and investigative authorities Par ParParPar Partially Compliant
32. Cash couriers LargLarLarLar Largely Compliant

10. 10
Ratings – technical compliance
(5/5)
September
2016
POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES
AND OTHER INSTITUTIONAL MEASURES (continued)
General Requirements
33. Statistics Par Pa ParPar Partially Compliant
34. Guidance and feedback Par Pa ParPar Partially Compliant
Sanctions
35. Sanctions Par Pa ParPar Partially Compliant
INTERNATIONAL COOPERATION
36. International instruments Par Pa ParPar Partially Compliant
37. Mutual legal assistance ComCo ComCom Compliant
38. Mutual legal assistance: freezing and confiscation Par ParParPar Partially Compliant
39. Extradition LargLarLarLar Largely Compliant
40. Other forms of international cooperation LargLarLarLar Largely Compliant

11. Anti-money laundering and counter-terrorist financing measures in Senegal – Mutual Evaluation Report – May 2018 11
Ratings – technical compliance