Financial Crime World

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Risk-Based Approach to Compliance in Gabon: A Complex Landscape

Gabon, a country located in Central Africa, has a complex anti-money laundering (AML) and combating the financing of terrorism (CFT) framework. While the country’s AML laws and regulations have been in place since 2005, the risk-based approach to compliance remains non-existent.

Regulatory Environment

The Banking Commission is the primary regulator for AML controls in Gabon’s banking sector. However, there are no clear guidelines or regulations on a risk-based approach to customer due diligence (CDD).

Key Challenges

  • Lack of publicly available information on Financial Action Task Force (FATF) mutual evaluation reports
  • No clear guidelines or regulations on risk-based approach to CDD

Customer Due Diligence

The requirements for customer identification information for individuals and corporates in Gabon are largely based on the verification of identity and address through official documents. Public officials require heightened scrutiny, and banks must collect additional information, including:

  • Anticipated account activity
  • Source of wealth
  • Sources of funds

Enhanced Due Diligence Measures

  • Required for correspondent banking relationships
  • Banks must ensure that their correspondents comply with AML regulations

Beneficial Ownership

The country’s AML regime requires banks to obtain information on beneficial owners but does not specify how this information should be verified.

Additional Requirements

  • Enhanced due diligence measures required for correspondent banking relationships

Politically Exposed Persons (PEPs)

Banks in Gabon must exercise heightened scrutiny when dealing with PEPs, including obtaining authorization from senior management before opening an account.

Key Considerations

  • Heightened scrutiny of PEPs
  • Obtaining authorization from senior management before opening an account

Risk-Based Approach

There is no risk-based approach approved by the local regulator, and banks are not required to implement a risk-based CDD framework. The country’s AML regime relies on a rules-based approach, which can lead to compliance fatigue and inefficiencies.

Consequences of Non-Compliance

  • Compliance fatigue
  • Inefficiencies in AML controls

Data Protection

Gabon has data protection laws in place, but they do not specifically address personal data or sensitive information.

Conclusion

While Gabon’s AML regime has made significant progress since 2005, the country’s lack of a risk-based approach to compliance remains a concern. Banks operating in Gabon must continue to implement robust CDD procedures and ensure that their AML controls are effective in mitigating money laundering and terrorist financing risks.