Cote d'Ivoire

Côte d’Ivoire, as a member of WAEMU, is subject to Regulation 06/2024/CM/WAEMU of December 20, 2024, which establishes dedicated exchange control rules for virtual assets, effectively creating a regulatory framework for virtual assets in the WAEMU zone.

**BCEAO's Cautious Stance:** The BCEAO has historically adopted a cautious, and at times prohibitive, stance towards cryptocurrencies due to concerns about monetary stability, consumer protection, money laundering, and illicit financing. They have issued warnings to financial institutions and the public about the risks associated with cryptocurrencies.

Côte d’Ivoire is subject to FATF recommendations and was assessed in an IMF-led 2023 report for compliance with FATF AML/CFT standards. It is also listed as a jurisdiction under increased FATF monitoring as of October 2025, indicating that FATF influence is already driving concrete actions to address strategic AML/CFT deficiencies, including for the regulation of VASPs.

**Required Licenses:** Approval as a **Payment Institution** or **Electronic Money Issuer (EME)** from the BCEAO.

**Directive No. 03/2018/CM/UEMOA** on the harmonization of the regulation of payment services in the UEMOA region.

**Instruction No. 002/2019/RB/UEMOA** relating to the approval of payment institutions and electronic money institutions.

*URLs:* These directives are typically found on the official BCEAO website, often in the "Texts & Regulations" or "Publications" sections.

BCEAO Official Website: https://www.bceao.int/ (You'd need to navigate to the "Textes & Réglementations" section to find the specific directives).

**Required Compliance:** Entities, even if not explicitly licensed for crypto, should adhere to general AML/CFT obligations if they deal with financial transactions. Once a specific VASP framework is established, these will be mandatory.

**Directive No. 02/2015/CM/UEMOA** on the fight against money laundering and terrorist financing in the UEMOA region.

*URL:* Again, available on the BCEAO website in the regulatory section.

**Required Registration:** Registration with the commercial registry (RCCM - Registre du Commerce et du Crédit Mobilier) and relevant tax authorities in Cote d'Ivoire.

**Current Status:** Largely unregulated for pure crypto-to-crypto exchanges. However, if they facilitate fiat-to-crypto or crypto-to-fiat transactions, they may face pressure from traditional banks (who are regulated by BCEAO) regarding AML/CFT compliance and potentially be required to obtain a Payment Institution license.

Côte d’Ivoire already has an established regulatory framework for food safety and documentation requirements, governed by multiple Ivorian government bodies, rather than a hypothetical future licensing regime.

Robust AML/KYC policies and procedures.

Strong cybersecurity and data protection measures.

**Current Status:** No specific regulation. Might be viewed as a financial service, but without clear licensing paths.

Advanced cybersecurity and cold/hot storage solutions.

Strong internal controls and audit.

**Current Status:** Most likely to fall under BCEAO's Payment Institution/EMI regulations *if* they facilitate electronic money issuance, transfers, or fiat conversions. Pure crypto-to-crypto payment processing without fiat involvement is currently unregulated but would still face AML/CFT scrutiny.

**Key Requirements (Under BCEAO PSP/EMI Regulation):**

**Capital:** Minimum capital requirements vary depending on the scope of activities. For Electronic Money Issuers, it can be substantial (e.g., in the billions of FCFA).

**AML/KYC:** Mandatory Customer Due Diligence (CDD) procedures, record-keeping, and suspicious transaction reporting (STR) to the national financial intelligence unit (CENTIF in Cote d'Ivoire).

**Local Presence:** Typically requires a locally incorporated entity and local management with expertise in financial services.

Governance structure in Côte d’Ivoire shows consolidated executive rule with weakened checks and balances, and risk management frameworks face ongoing economic vulnerabilities as noted in IMF reviews.

**Technical Infrastructure:** Secure and resilient IT systems for payment processing.

**Consumer Protection:** Measures to protect users' funds and ensure transparent service.

**Capital:** Varies significantly based on the type of license (Payment Institution vs. Electronic Money Issuer) and scope of activities. Can range from hundreds of millions to several billions of FCFA.

**AML/KYC:** Comprehensive policies and procedures in line with BCEAO and FATF standards. This includes CDD, enhanced CDD for high-risk clients, transaction monitoring, record-keeping, and reporting suspicious activities to CENTIF.

**Local Presence:** A locally incorporated legal entity in Cote d'Ivoire (or another UEMOA member state) is required, along with local management and operational staff.

**Governance & Risk Management:** Clear organizational structure, sound internal controls, risk management framework, and qualified management.

**Technical Infrastructure:** Secure and compliant IT systems.

**Preliminary Contact:** Initial discussions with BCEAO to understand requirements and specificities of the project.

Detailed business plan outlining services, target market, financial projections.

Legal documents (articles of incorporation, shareholders' agreements).

Organizational chart and CVs of key management personnel (fit and proper assessment).

Côte d'Ivoire has AML/CFT procedures, but following its October 2024 FATF grey-listing for strategic deficiencies, these procedures are considered insufficient and require further reform.

**Review and Due Diligence:** BCEAO conducts a thorough review of the application, which may include interviews, requests for additional information, and on-site inspections.

**Approval/Refusal:** If the application is deemed satisfactory, the BCEAO issues an approval decision. This can be a lengthy process, often taking several months to over a year.

**Post-Approval:** Ongoing reporting obligations, compliance with prudential rules, and regular audits.

**BCEAO Official Website:** https://www.bceao.int/ (Navigate to "Textes & Réglementations" for official documents)

**Directive No. 03/2018/CM/UEMOA:** On the harmonization of the regulation of payment services in the UEMOA region.

**Instruction No. 002/2019/RB/UEMOA:** Relating to the approval of payment institutions and electronic money institutions.

**Directive No. 02/2015/CM/UEMOA:** On the fight against money laundering and terrorist financing in the UEMOA region.

**Confers Rights Similar to Traditional Securities:** It grants rights to the holder that are analogous to those typically associated with shares (e.g., voting rights, dividend entitlements, participation in profits, liquidation rights), bonds (e.g., right to fixed or variable interest payments, repayment of principal), or units in collective investment schemes.

**Represents an Investment:** The primary purpose for acquiring the token is an expectation of financial return or profit derived from the efforts of others (e.g., the issuer, project developers). This implies an investment in a collective enterprise.

**Is Transferable:** It can be transferred or exchanged, often on secondary markets, although this is a characteristic of many digital assets, not solely securities.

**Security Tokens (Investment Tokens):** These are digital assets that meet the criteria described above. They represent traditional financial securities in a digital form. Examples would include:

Tokens representing equity in a company (tokenized shares).

Tokens representing a debt instrument (tokenized bonds).

Tokens granting a right to a share of future profits or revenue streams.

Tokens representing units in a collective investment scheme.

Any token that, due to its characteristics and the rights it confers, qualifies as a "security" under the CREPMF's organic texts.

**Utility Tokens (Payment Tokens or Access Tokens):** These are generally *not* considered securities if their primary purpose is to grant access to a product, service, or network within a defined ecosystem, and they do not confer rights analogous to financial securities or a direct expectation of profit from the issuer's efforts. For example, a token used to pay for transactions on a blockchain, or to access features of a software application. However, even utility tokens can be reclassified if marketed or structured in a way that suggests an investment motive.

**Hybrid Tokens:** Some tokens may combine characteristics of both security and utility tokens. In such cases, the CREPMF would likely apply a holistic assessment, leaning towards classifying it as a security if the investment component is significant.

**CREPMF Visa (Approval):** Any public offering of digital assets classified as securities within the UEMOA financial market requires a prior **visa (approval)** from the CREPMF. This is analogous to prospectus approval for traditional securities offerings.

**Prospectus Requirements:** The issuer must submit a detailed prospectus that provides comprehensive information, including:

Details about the issuer (legal status, financial situation, governance).

Description of the project or underlying asset.

Characteristics of the digital asset being offered (rights, technical specifications).

Use of proceeds from the offering.

Risk factors associated with the investment and the technology.

Information on the offering procedure, subscription terms, and trading conditions.

Legal opinions regarding the classification of the digital asset.

**Authorized Intermediaries:** The offering must be managed by financial intermediaries approved by the CREPMF.

**Information Disclosure:** Continuous information disclosure requirements apply post-issuance, similar to listed companies, to ensure market transparency.

**Private placements:** Offerings to a limited number of qualified investors or below a certain monetary threshold.

**Offerings to a restricted circle of persons:** Such as existing employees or board members, under specific conditions.

**Trading on Regulated Platforms:** Trading would likely need to occur on exchanges or multilateral trading facilities authorized and supervised by the CREPMF.

**Market Integrity Rules:** Adherence to rules preventing market manipulation, insider trading, and ensuring fair and orderly markets.

**Intermediary Role:** The involvement of authorized financial intermediaries (brokers, dealers) for executing trades.

**Transparency and Reporting:** Reporting requirements for transactions to the CREPMF.

**Nascent Market:** The market for security token offerings (STOs) is still in its early stages in the region.

**Focus on Fraud/AML:** Most enforcement actions or warnings by regulators in emerging markets regarding crypto tend to focus on:

**Fraudulent schemes/Ponzi schemes:** Where crypto is used as a lure for illicit activities.

**Unlicensed financial activities:** Issuance of fiat-pegged tokens (stablecoins) without proper licensing as a payment service or e-money institution.

**Anti-Money Laundering (AML) / Counter-Terrorist Financing (CFT) risks:** Warnings against unregulated crypto exchanges and service providers.

This is the primary source for all CREPMF regulations and guidance. You would need to navigate to the "Textes Réglementaires" or "Instructions" section.

**CREPMF Instruction No. 001/2021/PCMF/COS-UMOA of January 12, 2021, on the Regulation of Public Offerings of Digital Assets within the UEMOA Financial Market:**

While a direct public link to the PDF might not always be stable or readily available without searching within the CREPMF's document repository, this is the foundational text. You would typically find it listed under "Instructions" or "Règlementations" on the CREPMF website. *A specific direct URL is difficult to provide due to potential changes in document hosting, but searching for "Instruction 001/2021 CREPMF actifs numériques" on their site or via a search engine should yield results.*

**Key Requirements (Hypothetical/Future-oriented):** If regulated, would likely require:

**Ordonnance n°2019-1089 du 18 décembre 2019 portant modification de la Loi n°2014-393 du 20 juin 2014 relative à la lutte contre le blanchiment de capitaux et le financement du terrorisme.**

This Ordinance modified and strengthened the earlier Law n°2014-393, bringing it more in line with international standards set by FATF. It is the core legal text for AML/CFT.

This law defines "obliged entities" (assujettis) which include financial institutions, and potentially DNFBPs. While VASPs are not explicitly named, depending on the services offered, they could fall under these broad categories, particularly if they facilitate exchanges, transfers, or safekeeping of assets.

**Règlement n°07/2002/CM/UEMOA du 19 septembre 2002 relatif à la lutte contre le blanchiment de capitaux dans les États membres de l'UEMOA.**

This is a regional regulation by UEMOA, which member states like Cote d'Ivoire are required to transpose and apply. It provides the general framework for AML/CFT in the region.

The **BCEAO** has issued several communiqués warning against the use of cryptocurrencies (e.g., Communiqué du 12 décembre 2013, Communiqué du 05 décembre 2017, Communiqué du 22 mai 2018). These communiqués generally state that cryptocurrencies are not legal tender, are not regulated by the BCEAO, and carry significant risks. This stance means there is no formal licensing regime for VASPs in the UEMOA region, including Cote d'Ivoire, and operating in this space carries inherent regulatory ambiguity. However, the absence of specific regulation does not exempt entities from general AML/CFT obligations.

**Identification and Verification of Identity:**

**For Individuals:** Obtaining and verifying the customer's full name, date and place of birth, nationality, residential address, profession, and a unique identification number (e.g., national ID card, passport, driver's license). Verification must be based on reliable, independent source documents or data.

**For Legal Persons/Entities (e.g., businesses):** Obtaining and verifying the company's name, legal form, address of registered office, registration number, articles of incorporation, bylaws, and identifying the directors and persons authorized to represent the legal person.

**Beneficial Ownership:** Identifying and taking reasonable measures to verify the identity of the beneficial owner(s) (i.e., the natural person(s) who ultimately own or control the customer, or on whose behalf a transaction is being conducted). For legal persons, this typically involves identifying individuals holding 25% or more of the shares or voting rights, or otherwise exercising control.

**Purpose and Nature of the Business Relationship:** Understanding the purpose and intended nature of the business relationship or occasional transaction.

**Ongoing Monitoring:** Conducting ongoing due diligence on the business relationship and scrutinizing transactions undertaken throughout the course of that relationship to ensure that the transactions are consistent with the obliged entity's knowledge of the customer, their business, and risk profile.

**Enhanced Due Diligence (EDD):** Applying EDD measures in higher-risk situations, including:

Business relationships with Politically Exposed Persons (PEPs).

Complex, unusual, or large transactions.

Situations where the customer is not physically present for identification purposes (non-face-to-face transactions).

Transactions involving new technologies and products (which could include virtual assets) whose anonymity could favor ML/TF.

**Simplified Due Diligence (SDD):** Permitted in low-risk situations, as defined by regulation.

**Obligation to Report:** Obliged entities must report any transaction (or attempted transaction) that they suspect is linked to money laundering or terrorist financing to the Financial Intelligence Unit (FIU).

**Reporting Mechanism:** Reports are made to CELLIF (see below).

**Content of Report:** The report should include all available information concerning the customer, the transaction, and the reasons for suspicion.

**No Tipping-Off:** Obliged entities and their employees are prohibited from disclosing to the customer or to third parties that an STR has been filed or that an investigation is underway.

All customer identification data (e.g., copies of identification documents).

Account files and business correspondence.

Transaction data in a way that allows for reconstruction of individual transactions (including amounts, currencies, dates, sender/recipient details, and nature of the transaction).

The records must be kept for a minimum period of **five (5) years** after the end of the business relationship or after an occasional transaction. This period can be extended by legal or regulatory provisions.

**Cellule Nationale de Traitement des Informations Financières (CELLIF)**

**Role:** This is Cote d'Ivoire's Financial Intelligence Unit (FIU). It is responsible for receiving, analyzing, and disseminating suspicious transaction reports to competent authorities (e.g., law enforcement, judicial bodies). CELLIF is the central body for AML/CFT intelligence.

**Website (if available):** Accessing a specific official website for CELLIF can be challenging as many FIUs are integrated into a Ministry of Finance. However, information is often found on the Ministry's site or through GIABA:

While a direct, independent website for CELLIF may not be readily available or consistently maintained, information about Cote d'Ivoire's FIU and its contact details are often provided within the reports of international bodies like GIABA or the Egmont Group. For general information on FIUs in West Africa:

**Central Bank of West African States (BCEAO)**

**Role:** While not directly overseeing AML/CFT for *all* entities, the BCEAO is the regional central bank and plays a crucial role in regulating licensed financial institutions within UEMOA member states. For any entity providing payment services or operating in a manner that falls under traditional financial services (even if using virtual assets), the BCEAO's regulatory framework for financial institutions and payment systems would apply.

**No Specific VASP Licensing:** There is no dedicated licensing or regulatory framework for Virtual Asset Service Providers (VASPs) in Cote d'Ivoire or the broader UEMOA region.

**BCEAO Warning:** The BCEAO maintains a cautious stance, considering cryptocurrencies unregulated and risky. This creates a challenging environment for formal VASP operations.

**General AML/CFT Applies:** Any entity dealing with virtual assets, especially those providing services that resemble traditional financial activities (e.g., exchange, transfer, custody), should consider themselves an "obliged entity" under Cote d'Ivoire's AML/CFT laws (Ordonnance n°2019-1089) and comply with all CDD, STR, and record-keeping requirements. Non-compliance carries significant penalties.

**Regulatory Risk:** Operating without explicit authorization or a clear regulatory framework from the BCEAO or national authorities exposes VASPs to significant regulatory and legal risks, including potential future prohibitions or unexpected enforcement actions.

The BCEAO's formal position is articulated in its September 2021 communiqué warning against cryptocurrencies, which serves as the primary regulatory reference. While direct links to subsequent specific custody-related communiqués are not publicly available in English, the 2021 communiqué and BCEAO's broader publications on financial innovation (e.g., digital payments) consistently reiterate a cautious approach to non-fiat digital assets.

A widely cited stance, though not a specific custody rule, is their consistent warning against crypto:

*Example of reported BCEAO stance:* "The Central Bank of West African States (BCEAO) has reiterated its warning against cryptocurrencies, emphasizing that they are not legal tender in the WAEMU region and are not regulated by the Central Bank. The BCEAO has consistently advised the public to exercise extreme caution with these digital assets due to their speculative nature and lack of regulatory oversight." (This general statement reflects numerous communiqués over the years).

The BCEAO's official website (https://www.bceao.int/) designates its "Publications" and "News" sections, primarily in French, as the official channels for updates on its stance regarding digital currencies. No direct "custody regulation" document exists on the site as of this date.

There are no specific BCEAO licensing requirements for crypto custody, as cryptocurrencies are not recognized or regulated by the BCEAO. However, entities engaged in activities that intersect with traditional financial services (e.g., handling fiat currency, money transfers, or operating as a bank or payment institution) are subject to existing WAEMU financial licensing requirements, including AML/KYC obligations under the BCEAO's regulatory framework. National-level business licensing (e.g., registration with the Commercial Court in Côte d'Ivoire) also applies.

**Segregation of Client Assets Rules:**

The BCEAO's regulatory framework does not include specific rules for the segregation of cryptocurrency assets. While BCEAO regulations mandate segregation for fiduciaires in the traditional financial system (e.g., for securities maintained by investment service providers), these regulations explicitly exclude digital assets not recognized as financial instruments. Entities holding crypto assets may still be subject to general consumer protection or business contract laws at the national level in Côte d'Ivoire, but no specific segregation mandate from the BCEAO exists.

The BCEAO has not issued any mandates requiring insurance or bonding for digital asset custodians. This is consistent with the broader lack of regulation for crypto assets. However, entities that also operate as traditional financial institutions may be subject to existing insurance/bonding requirements for their licensed activities (e.g., operational risk insurance for banks), but these do not specifically cover crypto custody. The absence of such protections increases risk for users in the event of loss, theft, or custodian insolvency.

The BCEAO has not issued any specific mandates for cold storage or any other method of storing digital assets. This reflects the broader absence of a regulated crypto custody framework. In contrast, traditional financial institutions are subject to BCEAO prudential rules for the safekeeping of physical assets (e.g., cash in vaults, securities held by depositories), but no equivalent exists for unregulated digital assets.

**No specific definition for crypto assets.** The concept of a "qualified custodian" as defined in jurisdictions like the US (e.g., under the Advisers Act) does not exist for digital assets in Cote d'Ivoire, as there's no framework to define or regulate such entities.

**No publicly announced or specific pending custody legislation.** While there is a global trend towards regulating digital assets, and countries within Africa are increasingly exploring options, there is no public information or official announcement from Cote d'Ivoire or the BCEAO about specific pending legislation targeting cryptocurrency custody services. Any future regulation would likely come through the BCEAO at a regional level, possibly starting with AML/CFT (Anti-Money Laundering/Combating the Financing of Terrorism) frameworks before moving to market conduct or custody.

**Basis:** UN Security Council Resolutions are legally binding on all UN member states, including Côte d'Ivoire. These resolutions typically impose asset freezes, travel bans, and arms embargoes on individuals, entities, and countries deemed threats to international peace and security (e.g., related to terrorism, proliferation of weapons of mass destruction, specific regimes like North Korea or Iran).

**Asset Freeze:** VASPs must immediately freeze any virtual assets (and traditional assets) owned or controlled by designated individuals or entities.

**Prohibition:** Prohibit making any funds, virtual assets, or economic resources available to, or for the benefit of, sanctioned persons/entities.

**Reporting:** Report any frozen assets or attempted transactions involving sanctioned parties to the competent national authorities (e.g., the Financial Intelligence Unit - CENTIF).

**UN Security Council Sanctions Committees:** https://www.un.org/securitycouncil/sanctions/information

**Côte d'Ivoire's implementation:** While specific decrees implementing each UN resolution are many, the general obligation is enshrined in national laws for combating terrorism and money laundering.

**Basis:** OFAC administers and enforces economic and trade sanctions primarily against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States.

**Extraterritorial Reach:** OFAC sanctions can apply to non-U.S. persons (including VASPs) if:

They engage in transactions involving a U.S. person.

They use the U.S. financial system (e.g., USD stablecoins, or routing through U.S.-based entities).

They deal in property or interests in property that come within U.S. jurisdiction.

They engage in activities specifically prohibited by "secondary sanctions."

**Sanctioned Persons (SDN List):** Prohibit any transactions with individuals or entities on the Specially Designated Nationals and Blocked Persons (SDN) List. All property and interests in property of SDNs that are in the U.S. or come within the possession or control of a U.S. person must be blocked. This extends to virtual assets.

**Sanctioned Jurisdictions:** Restrict or prohibit transactions involving certain countries or regions (e.g., Iran, North Korea, Cuba, Syria, Crimea, Donetsk, Luhansk regions of Ukraine).

**Technology & Software:** Prohibit the provision of certain technology or software to sanctioned entities/jurisdictions.

**Reporting:** Report blocked transactions and rejected transactions to OFAC.

**OFAC Compliance Guidance for the Virtual Currency Industry:** https://ofac.treasury.gov/media/2529/download

**Basis:** The EU implements sanctions to pursue its foreign and security policy objectives, often reflecting UN Security Council resolutions, but also adopting autonomous sanctions (e.g., against Russia, Belarus, specific regimes, terrorism). These are binding on all EU citizens and entities. Given Côte d'Ivoire's historical ties to Europe, many VASPs in the region may have EU connections, clients, or partners.

**Asset Freeze:** Freeze all funds (including virtual assets) and economic resources belonging to, or owned or controlled by, designated persons, entities, or bodies.

**Prohibition:** Prohibit making any funds or economic resources available, directly or indirectly, to or for the benefit of, designated persons, entities, or bodies.

**EU Sanctions Map:** https://www.sanctionsmap.eu/#/main (Provides an overview of current EU sanctions regimes)

**Basis:** The Financial Action Task Force (FATF) sets international standards to prevent money laundering and terrorist financing. Côte d'Ivoire, through its membership in GIABA (a FATF-style regional body), is committed to implementing these standards. FATF has explicitly extended its recommendations to cover virtual assets and VASPs.

**Risk-Based Approach:** VASPs must assess and mitigate ML/TF risks, including sanctions risks.

**Customer Due Diligence (CDD) & Know Your Customer (KYC):** Obtain and verify customer identity, beneficial ownership, and purpose of business relationship.

**Transaction Monitoring:** Monitor transactions for suspicious activity, including potential sanctions evasion.

**Record-Keeping:** Maintain records of transactions and CDD information.

**Travel Rule:** For VA transfers above a certain threshold, VASPs must obtain and transmit required originator and beneficiary information.

**Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers (FATF):** https://www.fatf-gafi.org/publications/fatfrecommendations/documents/guidance-vasps.html

**Basis:** The Central Bank of West African States (BCEAO) issues regulations and directives for financial institutions within the UEMOA zone (which includes Côte d'Ivoire). These directives incorporate FATF standards for AML/CFT. While direct crypto-specific sanctions regulations from BCEAO are still developing, existing AML/CFT directives apply broadly to entities facilitating financial transactions.

Directive n°02-2015-CM-UEMOA relative à la lutte contre le blanchiment de capitaux et le financement du terrorisme is the current applicable text in Côte d'Ivoire, having replaced the 2007 directive.

**BCEAO Website:** https://www.bceao.int/ (Relevant publications are generally found under "Réglementation" or "Lutte contre le blanchiment de capitaux et le financement du terrorisme").

**Role:** CENTIF is Côte d'Ivoire's FIU responsible for receiving, analyzing, and disseminating suspicious transaction reports (STRs) and other information related to money laundering and terrorist financing to competent authorities. VASPs fall under its purview for reporting obligations.

**CENTIF Côte d'Ivoire Website:** https://www.centif.ci/

Implement systems to screen all customers, beneficial owners, counterparties, and transactions against international sanctions lists (UN, OFAC SDN, EU, and any relevant national lists).

Perform real-time and ongoing screening.

Ensure robust KYC/CDD procedures to identify ultimate beneficial owners.

Implement IP blocking, geo-fencing, and other technological controls to prevent services from being accessed or used by individuals/entities in sanctioned jurisdictions (e.g., Iran, North Korea, Cuba, Syria, and specific regions of Ukraine/Russia designated by OFAC/EU).

Refuse to onboard customers identified as residents of sanctioned countries.

Monitor all cryptocurrency transactions for red flags indicative of sanctions evasion (e.g., transactions with known sanctioned addresses, unusual transaction patterns, transactions linked to darknet markets or illicit mixers).

Refuse to process or block any transactions that involve sanctioned individuals, entities, or jurisdictions, directly or indirectly.

Ensure no virtual assets are provided to or for the benefit of sanctioned parties.

**Record-Keeping:** Maintain comprehensive records of screening checks, due diligence, and transaction monitoring activities for a minimum of five years.

**Reporting Obligations:** Report any sanctions hits, attempted sanctioned transactions, or suspicious activities to CENTIF immediately.

**Fines:** Significant monetary penalties for institutions and individuals.

**Imprisonment:** Individuals involved in serious breaches, particularly those related to terrorism financing or money laundering, can face lengthy prison sentences.

**Reputational Damage:** Severe harm to a VASP's reputation, leading to loss of customers and business opportunities.

**Operational Restrictions:** Potential revocation of licenses, prohibition from operating, or limitations on business activities.

**International Action:** Non-compliance with OFAC or EU sanctions can also lead to direct enforcement action by U.S. or EU authorities, including substantial fines and imprisonment for individuals, even if the primary operations are outside their direct jurisdiction, due to extraterritorial reach.

**National Anti-Terrorism List:** Côte d'Ivoire, through CENTIF and other security agencies, may maintain a national list of individuals and entities designated as terrorists or terrorist financiers based on intelligence and judicial processes. This list would be distinct from international lists but would also trigger asset freezes and prohibitions on all financial dealings, including those involving virtual assets. Such lists are typically not publicly available in a consolidated, easily accessible format for private entities but are communicated to financial institutions.