VZCZCXRO0246
PP RUEHMA RUEHPA
DE RUEHDK #0309/01 0380849
ZNR UUUUU ZZH
P 070849Z FEB 07
FM AMEMBASSY DAKAR
TO RUEHC/SECSTATE WASHDC PRIORITY 7522
RUEATRS/DEPT OF TREASURY WASHDC PRIORITY
INFO RUEHZK/ECOWAS COLLECTIVE
RUEHSA/AMEMBASSY PRETORIA 1993
RUEHJO/AMCONSUL JOHANNESBURG 0096
RUEHLMC/MCC WASHDC

UNCLAS SECTION 01 OF 02 DAKAR 000309 
 
SIPDIS 
 
SIPDIS 
 
STATE FOR INL, AF/RSA, AF/EPS, AF/W AND EB/ESC/TFS 
STATE ALSO FOR S/CT, INR/AA AND INR/B 
TREASURY FOR OTA AND FINCEN 
PARIS FOR POL - D'ELIA 
PRETORIA FOR TREASURY ATTACHE 
 
E.O. 12958: N/A 
TAGS: EFIN PTER ECON EAID PINR KCRM SG
SUBJECT: SENEGAL'S FIU (CENTIF) LAUNCHES NEW OUTREACH PROGRAM TO 
ENFORCE ANTI-MONEY LAUNDERING LAWS; COUNTERTERRORISM LAW PASSED 
 
DAKAR 00000309  001.2 OF 002 
 
 
¶1.  SUMMARY: NGouda Fall Kane, Director General of Senegal's 
Financial Intelligence Unit (FIU) the CENTIF, presided over a 
January 23 workshop, where he encouraged enhanced cooperation with 
different partners including the country's notaries public to 
strengthen the understanding and implementation of the West African 
Economic and Monetary Union (WAEMU) Uniform Law on Money Laundering 
(UL).  The participants included representatives from the Notaries' 
Association, the Bar Association, the Accountants' Association, the 
professional Bankers' Association, and senior officials from the 
Ministry of Finance, the Ministry of Justice, the West African 
Central Bank (BCEAO), customs, police, gendarmes, and 
nongovernmental organizations (NGOs).  The CENTIF plans to organize 
a series of meetings with other correspondents to reinforce 
cooperation and improve communication within the implementation 
framework of the UL, with a view towards significantly improving 
Senegal's anti-money laundering capabilities.  On January 31, the 
National Assembly adopted new counterterrorism legislation for which 
we have been pressing.  END SUMMARY. 
 
ENHANCING A COOPERATIVE AGREEMENT 
--------------------------------- 
¶2.  On January 23, Senegal's Financial Intelligence Unit (FIU), the 
CENTIF, organized and hosted a workshop covering issues on money 
laundering and the implementation of the WAEMU Uniform Law on Money 
Laundering.  This was the first major effort by the CENTIF since its 
establishment in August 2005 to publicly promote its role as one of 
Senegal's key AML organs.  NGouda Fall, Director General of the 
CENTIF, highlighted for the participants that the workshop 
represents a new strategy to enhance cooperation between CENTIF and 
its partners. 
 
¶3.  Fall emphasized the urgent need to close the communication gap 
between the different actors and to develop awareness program on the 
2005 Uniform Law (UL).  Fall stated that the UL must be applied to 
banking and non-banking financial institutions alike, and also to 
intermediaries such lawyers, accountants, notaries public, and 
brokers/dealers.  He pointed out that the law requires both 
financial and non-financial institutions to report all suspicious 
transactions as well as all transactions that involve at least 5 
million CFA francs (CFAF) (approximately USD 10,000) to the CENTIF. 
Fall expressed his appreciation for actions taken by some commercial 
banks as well as Senegal's Customs Service that provided information 
that allowed the CENTIF to initiate investigations on some 
suspicious cases.  For the notaries, who were the focus of this 
workshop, Fall encouraged compliance with the UL, and, in 
particular, to report real-estate transactions that involves at 
least five million CFAF. 
 
¶4.  At the workshop, a representative of Bankers Association 
explained that the majority of buildings under construction in Dakar 
are funded outside of the formal banking sector, stating that "we 
know the owners, but several of them have never applied for loans 
from commercial banks."  Participants noted with suspicion the large 
gap between the huge amounts of CFAF spent on building construction 
and the much smaller level of formal credit for housing disbursed by 
the banks. 
 
¶5.  Ahmadou NDiaye, President of the Notaries' Association, 
applauded the CENTIF's efforts to improve awareness and stated that 
his organization is ready to fully cooperate with the CENTIF in any 
suspicious transaction, including those involving the real-estate 
market, as well as in the establishment of new enterprises -- 
another area of concern highlighted by the CENTIF.  Ndiaye said that 
Senegal's buoyant real-estate market could create opportunities to 
recycle funds.  In particular, the growing market for luxury 
properties in upscale Dakar neighborhoods and at prime coastal 
locations does not appear, in a cursory analysis, to match local 
demand or financing flows from the formal sector.  NDiaye urged his 
members to develop "know your customer" principles and to fully 
comply with the UL practices. 
 
AN OPERATIONAL, BUT LIMITED FIU 
------------------------------- 
¶6.  The CENTIF has been operational since August 2005.  Though the 
new legislation largely meets international standards with respect 
to money laundering, it neither includes terrorist financing nor 
complies with all Financial Action Task Force (FATF) recommendations 
concerning politically exposed persons, and it lacks certain 
compliance provision for non-financial institutions.  Its three 
objectives aim to develop awareness program, detect suspicious 
transactions, and encourage international cooperation in money 
laundering.  The CENTIF has received technical assistance from the 
 
DAKAR 00000309  002.2 OF 002 
 
 
Office of Technical Assistance of the U.S. Department of Treasury 
and the French Treasury.  France is reportedly preparing to sponsor 
Senegal's FIU for Egmont Group membership. 
 
¶7.  In 2006, the CENTIF received 48 suspicious transactions 
declarations, and to date has referred six of these to the 
Prosecutor General.  All but two of the declarations have been made 
by banks.  The other two came from Senegal's Customs Service.  The 
FIU currently has a staff of 23, including six appointed members: 
the President who by law is chosen from the Ministry of Finance and 
five others detailed from the Customs Service, the BCEAO, the 
Judicial Police, and the judiciary. 
 
¶8.  The CENTIF is an administrative-type FIU.  It has full authority 
to request and obtain information from any correspondent or 
reporting entity whether it is public or private.  It can enlist the 
police or gendarmes for deepening investigations on suspicious 
cases.  It does not, at present, have regulatory responsibilities. 
Director General Fall stated that the CENTIF plans to organize 
similar workshops in 2007 targeting other non-financial players, 
including the Accountants' Association, the Bar Association, and 
Senegal's Customs Service. 
 
NEW COUNTERTERRORISM LEGILSATION ADOPTED 
---------------------------------------- 
¶9.  On January 31, the National Assembly adopted a new law that will 
grant increased powers to investigative authorities and allow up to 
30 years in prison or a life term of hard labor for those convicted 
on terrorism charges.  Welcoming the legislation, Senior Minister 
for Justice Cheikh Tidiane Sy explained that the "all states are 
vulnerable to the proliferation and frequency of terrorist attacks, 
which are being perpetrated by increasingly organized groups with 
sophisticated methods." 
 
COMMENT 
------- 
¶10.  There is no question that larges sums of money are flowing into 
Senegal from private sources, much of which is buying concrete, 
rebar, and high-end furnishings for the country's luxury residential 
housing boom.  Some of this money is no doubt from standard 
remittances from overseas family members.  Much of the rest is 
widely assumed to be sourced from illicit and politically-derived 
funds, both local and foreign.  Senegal has made considerable 
progress in establishing an operational FIU, and the CENTIF's new 
outreach approach is an important enhancement of its role, leading, 
we hope, to a marked improvement of Senegal's enforcement of 
existing AML laws.  However, even with a dedicated FIU, Senegal's 
deteriorating political climate in light of the 2007 presidential 
elections, and a generally non-transparent judiciary could retard 
any efforts to take this progress to the next level of actual 
prosecutions and convictions of money launderers.  Senegal needs to 
speed up reforms leading to greater transparency in the judicial, 
financial, and real estate sectors. 
 
BIOGRAPHIC NOTE - NGOUDA FALL KANE 
---------------------------------- 
¶10.  Mr. NGouda Fall Kane, was appointed Director General of the 
CENTIF in July 2004.  He is a Senior Executive Treasury Inspector. 
He graduated from the National School of Administration and Justice. 
 Born in 1952, Fall has 25 years of experience as a Tax Collection 
Officer at the Treasury Department in the Ministry of Economy and 
Finance.  Fall is widely considered honest and hard-working, and is 
well and favorably known within Senegal's financial community.  Fall 
has limited English. 
 
Jacobs