Cameroon -- Travel Rule Implementation Regulatory Overview

The implementation of the FATF Travel Rule (Recommendation 16) in Cameroon is significantly impacted by the regional ban on cryptocurrencies and related activities within the CEMAC (Communauté Économique et Monétaire de l'Afrique Centrale) zone, of which Cameroon is a member.

Here's a breakdown of the status:

1. Whether Adopted:

• No, the FATF Travel Rule has not been adopted for legally operating Virtual Asset Service Providers (VASPs) in Cameroon, because virtual asset activities and VASPs are currently prohibited.
• In May 2022, the Banque des États de l'Afrique Centrale (BEAC), the central bank for the CEMAC region (Cameroon, Central African Republic, Chad, Congo, Equatorial Guinea, Gabon), issued a Communiqué (No. 003/GR/2022) that formally banned all cryptocurrency activities in the zone. This communiqué prohibits the holding, buying, selling, and facilitation of transactions involving cryptocurrencies, effectively precluding the legal operation of VASPs.

2. Effective Date:

• Not applicable for legal VASP operations. Since virtual asset activities are banned, there are no legally recognized VASPs for whom the Travel Rule would apply or have an effective date.
• The BEAC Communiqué banning crypto activities came into effect immediately upon its publication in May 2022.

3. Threshold Amounts:

• Not applicable. As there are no legally operating VASPs, there are no established threshold amounts for the Travel Rule. (FATF Recommendation 16 typically suggests thresholds of USD/EUR 1,000 for transfers).

4. Which VASPs are Covered:

• None legally. The BEAC ban covers all entities and individuals involved in virtual asset activities, which would include any potential VASP (exchanges, custodians, etc.).

5. Technical Implementation Requirements:

• Not applicable. Without legal VASPs, there are no technical implementation requirements for the Travel Rule.

6. Penalties for Non-Compliance:

Penalties would primarily relate to:

• Violation of the BEAC Cryptocurrency Ban: Operating any virtual asset service provider or engaging in virtual asset transactions in the CEMAC region, including Cameroon, is a violation of the BEAC communiqué. While the communiqué itself might not detail specific penalties, it refers to existing monetary and financial regulations. This could lead to:

  • Financial penalties.
  • Imprisonment (under general financial crime laws).
  • Confiscation of assets.
  • Freezing of accounts.
  • Operational shutdown.

• General AML/CFT Violations: Even if virtual assets are illegal, illicit activities involving them (e.g., money laundering, terrorism financing) would still be prosecuted under Cameroon's existing Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) framework.

  • Cameroon's Law No. 2018/002 of 11 January 2018 on the Fight against Money Laundering and the Financing of Terrorism: This law outlines various offenses and penalties for money laundering and terrorism financing, including custodial sentences and substantial fines.
  • CEMAC Directive No. 01/03-UEAC-092-CM-07 (as amended): This regional directive also provides a framework for AML/CFT, which member states like Cameroon are expected to implement.

References:

• BEAC Communiqué No. 003/GR/2022 (May 2022): This is the core document. While a direct, stable public URL from the BEAC website can be elusive due to website updates, its existence and content have been widely reported by financial news outlets and legal firms specializing in African finance.
  • Example of reporting: "BEAC bans crypto assets in six countries of Central African Economic and Monetary Community" - https://cointelegraph.com/news/beac-bans-crypto-assets-in-six-countries-of-central-african-economic-and-monetary-community (Note: This is a news report, not the official communiqué, but it widely references the BEAC action).
• Law No. 2018/002 of 11 January 2018 on the Fight against Money Laundering and the Financing of Terrorism in Cameroon:
  • Often found on government legal portals or via legal research databases. A direct government URL can be hard to find consistently, but the law itself is publicly available.
  • Example of mention/summary: Consult publications from international organizations like the FATF or UNODC when they discuss Cameroon's AML framework, e.g., in mutual evaluation reports.
• FATF Mutual Evaluation Report for CEMAC (October 2020): While predating the explicit BEAC ban, this report highlights the AML/CFT framework of the region and any identified deficiencies, including the previous lack of specific regulation for virtual assets.
  • FATF Website - Mutual Evaluation of CEMAC (Look for the most recent CEMAC MER and follow-up reports).

In summary, Cameroon, as part of the CEMAC zone, has taken a prohibitive stance on virtual assets, meaning the FATF Travel Rule is not actively implemented for legal VASPs. Any engagement with virtual assets carries the risk of violating the central bank's ban, in addition to general AML/CFT laws if illicit funds are involved.