Financial Crime World

Combating Terrorist Financing in Togo: A Review of the Country’s Compliance with FATF Recommendations

The Financial Action Task Force (FATF) has recently evaluated Togo’s efforts to combat terrorist financing, and the results are a mixed bag. While the country has made significant progress in implementing some of the technical requirements outlined in the FATF Recommendations, there are still several areas where it falls short.

Compliance Status

According to the FATF ratings, Togo is largely compliant with recommendations R.1, R.2, and R.6, which relate to:

  • Assessing risk
  • National cooperation and coordination
  • Targeted financial sanctions related to terrorism and terrorist financing

Additionally, the country has made progress in implementing recommendations R.4, R.5, R.10, R.11, R.12, R.14, R.16, R.17, R.20, and R.26, which cover issues such as:

  • Confiscation and provisional measures
  • Money laundering and terrorist financing offenses
  • Customer due diligence
  • Record keeping
  • Regulation and supervision of financial institutions

Deficiencies

However, Togo has been rated partially compliant with recommendations R.3, R.7, R.9, R.13, R.15, R.22, R.24, R.25, R.28, and R.32, which relate to:

  • Money laundering offenses
  • Targeted financial sanctions related to proliferation
  • Financial institution secrecy laws
  • Correspondent banking
  • New technologies
  • DNFBPs customer due diligence
  • Transparency and beneficial ownership of legal persons and arrangements
  • Regulation and supervision of DNFBPs
  • Cash couriers
  • Statistics

Furthermore, the country has been found non-compliant with recommendations R.8, R.18, R.19, R.21, R.23, R.27, R.29, R.30, R.31, R.33, R.34, R.35, R.36, and R.39, which cover issues such as:

  • Non-profit organizations
  • Internal controls and foreign branches and subsidiaries
  • Higher-risk countries
  • Tipping-off and confidentiality
  • DNFBPs other measures
  • Regulation and supervision of financial institutions
  • Powers of supervisors
  • Financial intelligence units
  • Responsibilities of law enforcement and investigative authorities
  • Cash couriers
  • Statistics
  • Guidance and feedback
  • Sanctions
  • International instruments
  • Mutual legal assistance
  • Extradition
  • Other forms of international cooperation

Call to Action

The FATF has called on Togo to address these deficiencies and improve its overall compliance with the technical requirements outlined in the Recommendations. The country’s failure to do so could have serious consequences, including being placed on a list of countries subject to increased monitoring and scrutiny by the international community.

By addressing these issues, Togo can demonstrate its commitment to combating terrorist financing and preventing the misuse of its financial system for illicit purposes.