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Financial Institution Compliance Requirements in Togo: A Snapshot of the Country’s FATF Ratings

Togo, a West African country, has made significant strides in implementing the technical requirements of the Financial Action Task Force (FATF) recommendations. However, there are still areas where improvement is needed to ensure effective compliance.

FATF Ratings Overview

According to the latest follow-up report published by Benin in 2023, Togo’s ratings for each of the FATF Recommendations range from Compliant (C) to Non-Compliant (NC).

Risk Assessment and National Cooperation

  • Assessing risk and applying a risk-based approach received a rating of Largely Compliant (LC).
  • National cooperation and coordination also scored well, receiving an LC rating.

Confiscation and Provisional Measures

  • Togo’s efforts were deemed Partially Compliant (PC) in terms of confiscation and provisional measures.
  • Handling of targeted financial sanctions related to terrorism and terrorist financing received a rating of Largely Compliant (LC).
  • However, the country’s approach to non-profit organisations was deemed Non-Compliant (NC).

Financial Institution Requirements

  • Financial institution secrecy laws were rated Compliant (C).
  • Customer due diligence received a Partially Compliant (PC) rating.
  • Record keeping practices were deemed Largely Compliant (LC), as was handling of politically exposed persons.

Third Party and Internal Controls

  • The country’s reliance on third parties, internal controls, and foreign branches and subsidiaries all received Largely Compliant (LC) ratings.

Reporting of Suspicious Transactions and Confidentiality

  • Reporting of suspicious transactions received a Partially Compliant (PC) rating.
  • Tipping-off and confidentiality practices were deemed Compliant (C).

Transparency and Beneficial Ownership

  • Transparency and beneficial ownership of legal persons and arrangements received Non-Compliant (NC) ratings.

Regulation and Supervision of Financial Institutions

  • Regulation and supervision of financial institutions were deemed Partially Compliant (PC).
  • Approach to DNFBPs also received a PC rating.

International Cooperation and Law Enforcement

  • Financial intelligence units, law enforcement and investigative authorities, and cash couriers all received high ratings, with C ratings for powers of supervisors and C ratings for responsibilities of law enforcement and investigative authorities.

Conclusion

Overall, Togo’s compliance with FATF Recommendations is a mixed bag. While the country has made significant progress in some areas, there are still several areas where improvement is needed to ensure effective implementation.