VZCZCXRO0173
PP RUEHMA RUEHPA
DE RUEHDK #0457/01 0591253
ZNR UUUUU ZZH
P 281253Z FEB 07
FM AMEMBASSY DAKAR
TO RUEHC/SECSTATE WASHDC PRIORITY 7679
INFO RUEHZK/ECOWAS COLLECTIVE PRIORITY
RUEHSA/AMEMBASSY PRETORIA 2012
RUEATRS/DEPT OF TREASURY WASHDC
RHMCSUU/FBI WASHINGTON DC
RHEHNSC/NSC WASHDC
RUEAHLC/DEPT OF HOMELAND SECURITY WASHINGTON DC
RHFJUSC/US CUSTOMS SERVICE WASHDC
RUEHLMC/MCC WASHDC

UNCLAS SECTION 01 OF 03 DAKAR 000457 
 
SIPDIS 
 
SIPDIS 
SENSITIVE 
 
STATE FOR EB/ESC/TFS - KLEAHY AND LCANNON 
STATE ALSO FOR S/CT - PHILL, GALER AND NOVIS 
STATE ALSO FOR AF/RSA, AF/EPS AND AF/W 
TREASURY FOR OTA AND FINCEN 
PRETORIA FOR TREASURY ATTACHE 
PARIS FOR ICE RJOLLES 
 
E.O. 12958: N/A 
TAGS: EFIN ETTC KTFN PTER ECON EAID SG
SUBJECT: TERRORIST FINANCE: SENEGAL'S RESPONSE TO USG CONCERN OVER 
ILLICIT CASH COURIERS 
 
REF:  A. STATE 016120 
      ¶B. DAKAR 0309 (NOTAL) 
 
DAKAR 00000457  001.2 OF 003 
 
 
¶1.  (SBU) SUMMARY:  Per Ref A request, Econ Counselor met separately 
with Senegal's Financial Intelligence Unit (CENTIF), Senegal's 
Department of Customs, and ECOWAS' Inter-Governmental Action Group 
Against Money Laundering in West Africa (GIABA), to exchange views 
on the capacity and willingness of Senegalese authorities to address 
terrorist financing concerns and cash couriers.  Each of these 
organizations has a clear understanding of the risk posed by cash 
couriers and is implementing certain measures to better detect, 
report, and monitor such activity.  There was also a general 
agreement on the need for better interagency cooperation in Senegal 
and regionally.  There was unanimity among the agencies on the 
benefit of reinforcing bilateral cooperation with the U.S. Customs, 
OTA, and FBI experts to enhance anti-money laundering and 
counter-terrorist financing efforts.  END SUMMARY. 
 
THE CENTIF 
---------- 
¶2.  (SBU) In a February 20 meeting, NGouda Fall Kane, President of 
Senegal's Financial Intelligence Unit (CENTIF), told Econ Counselor 
that his organization is actively pursuing money laundering cases 
and is well attuned to the risks of bulk cash transactions for 
terrorist financing.  He noted that Senegal's AML Law gives the 
authority to Customs to control licit and illicit cash couriers, and 
to report and seize fraudulent transactions.  According to Kane, in 
general Senegalese Customs officers are well trained and equipped to 
monitor and interdict illicit cash couriers.  While overall 
cooperation between the two agencies is good, Customs could do a 
better job of quickly alerting the CENTIF to suspicious cases. 
 
¶3.  (SBU) West Africa Economic and Monetary Union (WAEMU/UEMOA) 
regulations require that any transit or transfer of currency greater 
than CFAF one million (USD 2,000) be declared to customs and 
reported to the CENTIF.  To date, the CENTIF has received 78 
suspicious declarations and has referred nine cases (three in 2005 
and six in 2006) to the Prosecutor General.  All but two of the 
declarations have been made by banks.  The other three came from 
Senegalese Customs.  Of the referrals, one is suspected of 
involvement in drug trafficking, one of diamond trafficking, one 
relates to tax fraud, and three are corruption-related.  No cases 
have concluded, although one arrest has been made. 
 
¶4.  (SBU) The CENTIF is currently very concerned about the growth of 
the informal cash couriers network in and through Senegal which, 
according to Kane, represent at least CFAF 500 billion (USD 1 
billion) per year.  Kane said that the growing presence of Hawala, 
Dakar's booming residential construction scene, and the increasing 
number of used, imported vehicles could be part of money laundering 
and illicit cash courier networks in Senegal.  In March, the CENTIF 
hopes to begin a study of the scope of bulk cash (and other bearer 
instruments).  Kane said that he would welcome any support from 
donors to in this effort. 
 
¶5.  (SBU) The CENTIF has established cooperative agreements with 
Belgium, France, Lebanon, Nigeria, Russia, Interpol, and the 
Senegalese "Inspection Generale de la Justice" to share intelligence 
and perform investigations.  Kane called for the embassy's support 
to enhance cooperation with FINCEN, the FBI, and the U.S. 
Immigration and Border Protection Service to monitor the financial 
flow into Senegal from Senegalese expatriates living in the U.S. 
 
¶6.  (SBU) He applauded Senegal's new counterterrorism law, approved 
on January 31, 2007, that includes enhanced authority to combat 
terrorist financing and authorizes the Ministry of Finance to 
monitor and control of NGO funds entering and leaving the country. 
With this law in place, the CENTIF's proposed membership to the 
EGMONT group will likely move forward, with sponsorship by France, 
according to Kane. 
 
¶7.  (U) The regional central bank (Banque Centrale des Etats de 
l'Afrique de l'Ouest - BCEAO) has already finalized a "Directive 
against Terrorist Financing" to be presented to the WAEMU Council of 
Ministers in March 2007.  Once, adopted, the member states would be 
directed to enact a law against terrorist financing, which most 
 
DAKAR 00000457  002.2 OF 003 
 
 
likely would be presented as a Uniform Law in the same manner as the 
2005 WAEMU AML law.  Because, like the AML law, the terrorist 
financing legislation would include criminal penalties each WAEMU 
nation must enact enabling legislation to adopt the law.  This 
follow-on step should not be difficult in Senegal's case, Kane 
stated. 
 
¶8.  (U) As reported in Ref B, Kane highlighted the CENTIF's plans to 
host programs for local travel agencies and other non-financial 
institutions to raise awareness on the cash courier issues and 
regulations.  Kane added that he would welcome any support from the 
U.S. Customs or OTA to bring in a U.S. expert for a day workshop on 
financial investigations regarding cash smuggling and money 
laundering/terrorism financing. 
 
SENEGAL CUSTOM'S SERVICE 
------------------------ 
¶9.  (SBU) On February 22, Colonel Mouhamadou Moustapha Diagne, 
Director of Intelligence and Fraud for Senegal's Department of 
Customs, explained that the majority of Customs agents understand 
the requirements for declarations on cash entering and leaving the 
country.  According to Diagne, in general, Senegal's Customs Service 
is well equipped to adequately address the cash couriers, by 
investigating, detecting, restraining, confiscating the suspect 
physical cross-border movement of funds.  At Dakar's Leopold Sedar 
Senghor International Airport, Customs use a sophisticated X-ray 
machine to detect concealed cash.  At the same time, Diagne 
recognizes cash couriers are a significant risk and that the Service 
needs to improve its detection and investigations capabilities and 
enhance its role domestically, regionally and multilaterally. 
According to Diagne, Customs personnel are reporting all seizure of 
money, gold and other bearer instrument to the CENTIF (while 
admittedly not providing every suspect declaration in a timely 
manner). 
 
¶10.  (SBU) Diagne added that Senegal is ready to implement FATF 
special recommendations, and that in the near future Customs is 
planning to establish a new financial investigation unit -- and 
would highly appreciate any training from U.S. Customs and Border 
Protection Department (CBP) on cash smuggling detection as well as 
training on financial investigation methods. 
 
¶11.  (U) NOTE:  Senegal Custom's service, part of the Ministry of 
Finance, has established cooperative training agreement with the 
CBP, which has provided border enforcement trainings for air and 
maritime environments in September 2006 and January 2007, 
respectively.  CBP is planning to organize the third training on 
targeting and risk management in late April.  END NOTE. 
 
GIABA 
----- 
¶12.  (SBU) The Governmental Action Group Against Money Laundering in 
West Africa (GIABA) is the FATF-style regional body for the 
15-member Economic Community of Western African States (ECOWAS).  On 
February 13, Doctor Abdullahi Y. Shehu and Doctor NDeye Elisabeth 
NDiaye, respectively GIABA's Administrative Secretary and Deputy 
Administrative Secretary said that the region needs to significantly 
enhance the detection and reporting of cash couriers.  Shehu 
highlighted GIABA's role as an FSRB to create a typology program on 
cash transfers and couriers.  He explained that ECOWAS countries are 
required to submit regular reports on cash courier activities to 
GIABA.  In addition, Shehu noted that in December, GIABA hosted an 
initial meeting for member states to begin a work plan on this 
topic, including systematic data collection and the presentation of 
case studies.  Shehu hopes to begin this program at an April 
workshop in 2007, and consolidate it during the June ECOWAS Plenary. 
 (NOTE:  Shehu said he would welcome the participation of U.S. 
Treasury and/or other U.S. Agencies at the April workshop, adding 
that he would send a formal invitation "soon."  END NOTE.) 
 
¶13.  (SBU) The establishment of working Financial Intelligence Units 
(FIU) within ECOWAS was a very positive trend, according to Shehu. 
In addition to Senegal's CENTIF, Shehu said that Nigeria and Niger 
had operational FIUs, and were receiving significant assistance from 
the European Union and the U.N. Office of Drugs and Crime (UNODC), 
respectfully.  He added that Sierra Leone, Liberia, Cape Verde, The 
 
DAKAR 00000457  003.2 OF 003 
 
 
Gambia, Guinea Bissau, and Cote d'Ivoire are all making progress on 
standing-up FIUs (although he had not yet met with the officials in 
Bissau or Abidjan).  According to Shehu, Ghana is the furthest 
behind, and has not yet taken even preliminary steps for the 
creation of an FIU or for enacting the ECOWAS AML law. 
 
¶14.  (SBU) Regarding implementing systems targeting illicit cash 
leaving as well as entering a jurisdiction, Shehu thought that 
Senegal, Nigeria, and Cote d'Ivoire had declaration requirements for 
money both entering and leaving their borders.  (NOTE:  This is true 
for Senegal, but Embassy has not confirmed the reporting 
requirements for other countries.  END NOTE.)  Shehu also expressed 
an interest in working with the OTA experts on training programs to 
assist customs and law enforcement organizations in detecting cash 
smuggling.  He also envisioned a possible FBI role in assisting 
member states with intelligence sharing. 
 
¶15.  (SBU) Mrs. Diaw, who has a strong background in financial law, 
highlighted the problem of "open borders" for the eight West African 
Economic and Monetary Union (WAEMU) countries (Benin, Burkina Faso, 
Cote d'Ivoire, Guinea Bissau, Mali, Niger, Senegal and Togo), and 
also the threat posed by terrorist groups to use NGOs for 
fundraising and money laundering.  She is the main author of the 
draft "Legal Framework on the Combat against the Financing of 
Terrorism in the ECOWAS Member States," which was presented at a 
November 21-23 conference in Niamey.  The draft framework includes 
monitoring and reporting requirements for cash couriers and for 
NGOs, and is designed to strengthen the existing GIABA AML 
framework.  UNODC experts are providing technical assistance to 
review the draft.  Mrs. Diaw is guardedly optimistic that the final 
draft framework will be adapted during the planned ECOWAS plenary in 
June. 
 
¶16.  (SBU) NOTE:  Over much of 2005-2006 a U.S. Treasury advisor 
consulted with GIABA and currently, GIABA and Treasury are 
negotiating Terms of Reference for the possible return to Dakar of 
another advisor to work closely with GIABA.  Shehu was guardedly 
optimistic that an agreement on the TOR could be reached soon and 
that the final agreement reviewed and approved during the ECOWAS 
summit in June 2007.  END NOTE. 
 
¶17.  (SBU) BIOGRAPHIC NOTE:  Ndeye Elisabeth Diaw is a BCEAO 
official seconded to GIABA.  She holds a Doctor of Law degree; she 
served at the BCEAO Headquarters in Dakar as the Director of 
International Division, and later as the Director of Legal 
Department and Senior Advisor to the Governor in charge of Money 
Laundering and Terrorism Financing. 
 
COMMENT 
------- 
¶18.  (SBU) Any discussion of financial regulation and enforcement in 
West Africa is incomplete with consideration of the impact of 
corruption.  Anecdotal reports of corruption among officials at air 
and sea ports are widespread.  Cash transactions are more the norm 
than the exception, in large part due to the lack of confidence in 
and accessibility to commercial banks.  Distinguishing money 
laundering or terrorist financing from culturally accepted business 
practices will remain difficult, and likely, prone to political 
influence. 
 
¶19.  (U) Visit Embassy Dakar's classified website at 
http://www.state.sgov/gov/p/af/dakar/. 
 
Jacobs