Togo AML & CFT Compliance Guide (2025) | Anqa

Togo AML/CFT & Sanctions Compliance Guide

Navigate Togo's evolving financial regulatory landscape with Anqa's comprehensive compliance solutions designed for West Africa's emerging financial sector.

AML/CFT Overview in Togo

Togo has strengthened its AML/CFT framework in recent years, with the Central Bank of West African States (BCEAO) and the National Financial Information Processing Unit (CENTIF) as the primary regulators overseeing the financial sector.

Togo's AML/CFT Regulatory Framework

Key AML/CFT Regulators

Togo's AML/CFT framework establishes the legal and operational mechanisms for preventing, detecting, and prosecuting financial crimes, aligning with regional and international standards.

Togo's AML/CFT framework is primarily governed by the Law on the Prevention and Suppression of Money Laundering and Terrorism Financing (Law No. 2018-16) and supporting regulations issued by:

  • National Financial Information Processing Unit (CENTIF): Financial intelligence unit.

    Key Focus: Focus on improving the quality and analytics of STR/CTR submissions from DNFBPs.

  • Central Bank of West African States (BCEAO): Regional central bank.

    Key Focus: Emphasis on digital KYC, sanctions screening for forex transactions, and VASP regulation.

  • Banking Commission of WAEMU: Regional banking supervisor.
  • Insurance Control Commission (CAC): Insurance regulator.

FATF Status & Engagement

FATF Public List Status (June 2025): Not currently listed on FATF's black or grey lists.

Summary of FATF Standing & Key Issues

Togo is a member of the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA) and is subject to its mutual evaluation process.

For detailed assessment information, refer to its Mutual Evaluation Report. Its 3rd Enhanced Follow-Up Report was anticipated in 2025 by GIABA.

Key References/Verification

Key AML/CFT Compliance Requirements in Togo

Financial institutions and DNFBPs in Togo must adhere to a comprehensive set of AML/CFT obligations to mitigate financial crime risks effectively.

Core Obligations

  • CDD/KYC: Financial institutions must conduct risk-based customer due diligence. Enhanced due diligence required for high-risk customers, including PEPs, with particular attention to port operations, cross-border trade, and free trade zones.
  • Beneficial Ownership: Requirements to identify and verify beneficial owners with a threshold of 25% ownership or effective control. Implementation has been strengthened with the creation of a beneficial ownership registry.
  • Transaction Monitoring: Financial institutions must implement automated systems to detect suspicious transactions, with specific attention to port-related payments exceeding 5 million CFA francs.
  • Record Keeping: Minimum 10-year retention period for all customer records and transactions, with specific requirements for port-related documentation and free trade zone transactions.
  • Reporting: Suspicious Transaction Reports (STRs) must be filed with CENTIF within 48 hours of detection. Cash Transaction Reports required for transactions exceeding 5 million CFA francs.

Key Challenges (Operational)

  • Port Operations: Complex port operations and related financial flows creating specific money laundering vulnerabilities.
  • Cross-Border Trade: Extensive cross-border trade requiring enhanced due diligence, particularly with neighboring countries.
  • Free Trade Zones: Multiple free trade zones requiring sophisticated monitoring of business activities and financial flows.
  • Implementation Gaps: Inconsistent application of AML/CFT requirements across different financial sectors.
  • Digital Finance: Rapid growth of mobile money and digital financial services requiring enhanced monitoring.

Sanctions Compliance Considerations for Togo

Togo implements UN sanctions through domestic legislation. Financial institutions must maintain vigilance with respect to transactions linked to port operations, cross-border trade, and free trade zones. Particular attention should be paid to transactions involving high-risk sectors and correspondent banking relationships.

Financial institutions should apply enhanced due diligence to transactions involving PEPs and state-owned enterprises, particularly in sectors vulnerable to financial crimes due to limited oversight and enforcement capacity.

Key Compliance Challenges in Togo

Understanding the unique obstacles facing financial institutions in Togo

1

Navigating Port Operation Risks

Complex port operations and related financial flows create specific money laundering vulnerabilities, requiring enhanced monitoring of maritime transactions and port-related payments.

2

Managing Cross-Border Trade Compliance

Extensive cross-border trade requires sophisticated monitoring systems and enhanced due diligence procedures, particularly with neighboring countries.

3

Overseeing Free Trade Zone Activities

Multiple free trade zones require enhanced monitoring of business activities and financial flows, with specific attention to commercial operations.

4

Addressing Regulatory Implementation Gaps

Inconsistent application of AML/CFT requirements across different financial sectors creates challenges in maintaining uniform compliance standards.

5

Securing the Digital Finance Ecosystem

Rapid growth of mobile money and digital financial services requires enhanced monitoring and sophisticated risk management strategies.

6

Overcoming Resource and Enforcement Constraints

Limited resources for supervision and enforcement despite strengthened legal framework, requiring financial institutions to implement robust internal controls and compliance programs.

Anqa's Tailored Approach for Togo

Our comprehensive AML solution tailored for Togo's unique regulatory landscape and market requirements, incorporating Law No. 2018-16 and CENTIF guidelines.

1

Port & Free Trade Zone KYC Hub

Centralized KYC CRM with selfie capture and document storage specifically designed for Togo's port operations and free trade zones, including electronic onboarding with customer consent and eKYC invites for port operators.

Benefit: Ensures compliance with CENTIF requirements for high-risk port and FTZ entities, streamlining due diligence.

2

Port-Specific Risk Assessment

Advanced risk assessment tool analyzing geography, transaction volumes, and institutional exposure, with special focus on port operations and cross-border activities.

Benefit: Provides targeted risk insights crucial for Togo's trade-heavy economy, aligning with Law No. 2018-16.

3

Multi-List Screening (WAEMU Focus)

Comprehensive screening against global watchlists, WAEMU regional lists, and customer-specific internal watchlists, with clear alert match grading for fast resolution of port-related transactions.

Benefit: Facilitates compliance with regional (WAEMU) and international sanctions, crucial for Togo's financial sector.

4

Digital Finance Compliance

Specialized tools for monitoring digital financial services, including selfie capture for onboarding and relationship records for mobile money operations.

Benefit: Addresses risks in Togo's growing digital finance sector, ensuring KYC/AML for new payment methods.

5

Regional Integration & Reporting

WAEMU-compliant reporting and monitoring tools for cross-border transactions, with enhanced focus on port operations and free trade zone activities. Automated generation of STRs/CTRs for CENTIF.

Benefit: Supports seamless compliance and reporting across WAEMU, vital for Togo's financial activities.

6

Localized Deployment & Support

Cloud-based deployment with scalable licensing options, supporting online and agent-based operations. Platform interface and expert support available in French to assist Togolese teams.

Benefit: Offers flexible, accessible solutions with local language support for Togolese institutions.

Anqa: Partnering for AML/CFT Excellence in Togo

Anqa is dedicated to empowering Togo's financial institutions and DNFBPs in their fight against financial crime. Our platform is tailored to address the specific challenges of the Togolese market, such as the complexities of port operations, extensive cross-border trade, and the unique risks associated with Free Trade Zones, all within the framework of Law No. 2018-16 and CENTIF guidelines.

By integrating localized solutions, including French language support and a focus on WAEMU regional compliance, Anqa aims to enhance the effectiveness of AML/CFT measures in Togo. We strive to help Togolese entities build robust compliance programs, strengthen their risk management capabilities, and contribute to the integrity and growth of Togo's financial system within the West African economic landscape.

Togo — AML & Compliance FAQs

  • Banks, MFIs, mobile money operators, and crypto platforms must perform customer due diligence, assess risk, file suspicious transaction reports, and maintain detailed records under CENTIF-Togo oversight.

  • Yes. Accountants, auditors, and virtual asset service providers are required to implement KYC, monitor transactions, and report any suspicious or irregular activity.

  • The Cellule Nationale de Traitement des Informations Financières (CENTIF-Togo) is the financial intelligence unit responsible for AML enforcement, data analysis, and international coordination.

  • NGOs handling donor funds or cross-border remittances must conduct beneficiary screening, assess risk, and ensure transparency to prevent misuse of financial flows.

  • Anqa offers accessible tools for digital onboarding, customer risk scoring, and sanctions list screening — helping small firms meet AML expectations without heavy IT infrastructure.