Compliance Guide 2025
Cameroon AML & Sanctions Compliance Guide 2025
Comprehensive guide to navigating Cameroon's AML/CFT and sanctions compliance landscape
Overview
Country Profile
Cameroon is a member of the Central African Economic and Monetary Community (CEMAC) with a developing financial sector. Key institutions include:
- Bank of Central African States (BEAC) - Regional central bank
- National Financial Investigation Agency (ANIF)
- Ministry of Finance
- Banking Commission of Central Africa (COBAC)
Regulatory Framework
- Law No. 2014/028 on the Prevention and Suppression of Money Laundering
- Law No. 2014/027 on the Prevention and Suppression of Terrorism Financing
- COBAC Regulation R-2014/01 on AML/CFT
- Decree No. 2015/187 on Beneficial Ownership
Key points:
- Mandatory KYC/CDD requirements
- Enhanced due diligence for PEPs and high-risk clients
- Data retention: minimum of 10 years
- Mandatory STR filing for suspicious transactions
FATF Status
Currently under increased monitoring
Cameroon is on the FATF list of Jurisdictions under Increased Monitoring (the "grey list"), confirmed at the plenary of 19 June 2026. Cameroon works with GABAC, the FATF-style regional body for Central Africa, on an agreed action plan.
Practical consequence: correspondent banks and EU-regulated counterparties are expected to apply enhanced due diligence to Cameroon-linked business. Institutions should document country risk explicitly, expect additional information requests on cross-border payments, and track each plenary for changes to the action plan.
Compliance Requirements
Sanctions Regime
Cameroon implements UN sanctions and maintains domestic sanctions lists.
- Regular screening against UN and local watchlists
- Immediate asset freeze requirements
- Reporting obligations to ANIF
- Compliance with both CEMAC and international sanctions regimes
Risk Environment
Typologies:
- Corruption and bribery
- Trade-based money laundering
- Cash-based transactions
- Politically exposed persons (PEPs)
High-risk sectors: Banking, real estate, casinos, money remittance
Regulatory Details
Reporting Requirements
Thresholds and Timelines:
- STR filing: declared to ANIF under CEMAC Regulation 01/CEMAC/UMAC/CM (2016); oral declarations must be confirmed in writing — confirm the applicable period with ANIF
- CTR (Currency Transaction Report): confirm the current CEMAC/ANIF threshold — figures in circulation differ
- PEP reporting: Mandatory for domestic and foreign PEPs
- Annual compliance reports: Due March 31st
Penalties:
- Non-compliance fines: Up to XAF 100,000,000
- License revocation for repeated violations
- Criminal liability for willful non-compliance
Data Protection & Privacy
- Law No. 2010/012 on cybersecurity and cybercrime — data handling and record security obligations
- Mandatory data localization for financial records
- 10-year retention period for customer records
- Secure storage requirements for sensitive data
- Breach notification — confirm the statutory window under local data protection law
Implementation Guidance
Compliance Program
- Comprehensive KYC procedures
- Regular staff training programs
- Transaction monitoring systems
- PEP screening and enhanced due diligence
- Regular risk assessments
Supervisory Trends
- Increased focus on beneficial ownership transparency
- Enhanced scrutiny of cross-border transactions
- Stricter enforcement of KYC requirements
- Regular on-site inspections by COBAC
Operational Considerations
Risk Assessment Framework
Required Elements:
- Customer risk scoring methodology
- Product and service risk assessment
- Geographic risk factors
- Transaction pattern analysis
- Regular risk review cycles (minimum quarterly)
Documentation Requirements:
- Risk assessment methodology documentation
- Risk scoring criteria and thresholds
- Review and approval records
Staff Training Requirements
Mandatory Training Topics:
- AML/CFT laws and regulations
- KYC and CDD procedures
- Sanctions screening
- Red flag indicators
- Reporting obligations
Training Frequency:
- New staff: Within 30 days of joining
- Annual refresher training
- Role-specific training for compliance staff
Technology & Systems
System Requirements
Recommended Systems:
- Basic transaction monitoring capabilities
- Manual or automated sanctions screening tools
- Customer risk assessment templates
- Document management system
- Basic reporting tools
Key Considerations:
- Systems should support French language
- Ability to generate reports in required formats
- Basic audit trail functionality
- Secure storage for customer documentation
- Compatibility with local reporting requirements
Record Keeping
Documentation Requirements:
- Customer identification records
- Transaction records and supporting documents
- Risk assessment documentation
- Training records and certifications
- Internal audit reports
Retention Periods:
- Customer records: 10 years after relationship ends
- Transaction records: 10 years from date of transaction
- Training records: 5 years
- Audit reports: 10 years
Industry-Specific Requirements
Financial Sector
Banks & Financial Institutions:
- Enhanced due diligence for correspondent banking
- Special monitoring for high-risk transactions
- Strict wire transfer regulations
- Mandatory reporting of cross-border transactions
Insurance Sector:
- Special focus on life insurance products
- Enhanced monitoring of large premium payments
- Specific requirements for policy beneficiaries
Other Regulated Sectors
Real Estate:
- Mandatory reporting of cash transactions
- Enhanced due diligence for high-value properties
- Special attention to offshore buyers
Gaming & Casinos:
- Strict monitoring of gaming transactions
- Mandatory reporting of large wins
- Enhanced due diligence for VIP customers
Cross-Border Considerations
International Transactions
Key Requirements:
- Enhanced due diligence for cross-border wire transfers
- Mandatory reporting of international transactions above XAF 2,000,000
- Special attention to transactions with high-risk jurisdictions
- Documentation of foreign exchange transactions
- Compliance with both CEMAC and international sanctions regimes
Correspondent Banking:
- Strict due diligence on foreign correspondent banks
- Regular review of correspondent banking relationships
- Monitoring of nested account activities
- Documentation of foreign bank certifications
Trade Finance
Documentation Requirements:
- Detailed trade documentation for all transactions
- Verification of shipping documents
- Commodity price verification
- Beneficiary verification
Risk Mitigation:
- Regular review of trade finance patterns
- Enhanced monitoring of high-value transactions
- Special attention to dual-use goods
- Documentation of trade finance controls
Compliance Challenges & Solutions
Common Challenges
Operational Challenges:
- Limited access to reliable customer data
- High volume of cash transactions
- Complex ownership structures
- Language barriers in documentation
- Limited technological infrastructure
Regulatory Challenges:
- Frequent regulatory changes
- Inconsistent enforcement
- Limited regulatory guidance
- Complex reporting requirements
Practical Solutions
Operational Solutions:
- Implement robust data collection processes
- Develop cash transaction monitoring systems
- Create standardized documentation templates
- Invest in translation services
- Build local compliance expertise
Regulatory Solutions:
- Regular regulatory updates and training
- Proactive engagement with regulators
- Documentation of compliance decisions
- Implementation of automated reporting systems
Regulator Engagement
Best Practices
Communication Strategies:
- Regular meetings with regulatory contacts
- Proactive reporting of issues
- Clear documentation of compliance efforts
- Timely response to regulatory inquiries
- Maintenance of regulatory relationship logs
Examination Preparation:
- Maintain organized compliance documentation
- Conduct regular internal audits
- Prepare executive summaries of compliance programs
- Train staff on examination procedures
Regulatory Reporting
Effective Reporting:
- Establish clear reporting timelines
- Implement quality control for reports
- Maintain reporting logs and acknowledgments
- Document any reporting delays or issues
Relationship Management:
- Designate primary regulatory contacts
- Maintain regulator contact database
- Document all regulatory communications
- Regular review of regulatory relationships
Practical Guidance
Practical Tips
Red Flags:
- Large cash transactions without clear source
- Complex transaction structures
- Unusual cross-border transfers
- Reluctance to provide KYC documentation
Local Considerations:
- Understand local business practices
- Be aware of cash-based economy aspects
- Maintain strong relationships with regulators