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TO RUEHC/SECSTATE WASHDC PRIORITY 9955
INFO RUEHZK/ECOWAS COLLECTIVE PRIORITY
RUEAWJA/DEPT OF JUSTICE WASHDC PRIORITY
RUEATRS/DEPT OF TREASURY WASHDC
RHEHNSC/NSC WASHDC
RUEAHLC/DEPT OF HOMELAND SECURITY WASHINGTON DC
RHMCSUU/FBI WASHINGTON DC
RHEFDIA/DIA WASHINGTON DC
RHMFIUU/HQ USAFRICOM STUTTGART GE
RHMFIUU/HQ USEUCOM VAIHINGEN GE//ECJ2//
RHMFIUU/HQ USEUCOM VAIHINGEN GE//ECJ3//
RHMFIUU/HQ USEUCOM VAIHINGEN GE//ECJ4//
RHMFIUU/HQ USEUCOM VAIHINGEN GE//ECJ5//

UNCLAS SECTION 01 OF 08 DAKAR 000126 
 
SIPDIS 
 
SIPDIS 
SENSITIVE 
 
STATE FOR S/CT, INL, AF/RSA, AF/W, EB/ESC/TFS AND INR/AA 
JUSTICE FOR AFMLS, OIA AND OPDAT 
TREASURY FOR FINCEN 
 
E.O. 12958: N/A 
TAGS: EFIN KTFN PTER KCRM PREL SNAR PGOV SG
SUBJECT:  RESULTS OF FINANCIAL SYSTEMS ASSESSMENT TEAM VISIT TO 
SENEGAL (SECOND OF TWO CABLES) 
 
REF:  DAKAR 125 
 
DAKAR 00000126  001.3 OF 008 
 
 
NOTE:  This cable is Part II of two-part report.  See Reftel for 
Part I. 
 
FINANCIAL INSTITUTIONS ARE OBLIGED TO ACT 
----------------------------------------- 
¶30.  (U) The Uniform Law obliges the public treasury, the BCEAO, 
financial institutions, and "producers of business for financial 
institutions" to file STRs.  Other obliged entities include:  banks, 
auditors, real estate agents, notaries, dealers in high-value items, 
cash transporters, owners, directors, and managers of casinos and 
gambling establishments (including national lotteries), travel 
agencies, and NGOs.  Members of the independent legal professions 
are also covered.  Correspondents from other ministries and the 
private sector are required to collect and report financial 
intelligence to the CENTIF.  By statute, the entire range of 
financial institutions are required to send STRs to the CENTIF. 
 
¶31.  (U) BCEAO examiners review AML programs (in addition to the 
regulatory safety and soundness examinations performed by the BC) 
but do not address underlying inequalities.  Under the Uniform Law, 
each bank is required to have a compliance officer responsible for 
that bank's AML program.  However, not all banks have designated 
this officer.  Similarly, as of 2007, the BCEAO and the BC require 
an annual report on banks' AML programs, but not all banks have an 
AML program in place. 
 
¶32.  (SBU) The sector today lacks a uniform minimum level of 
understanding, knowledge, and standard of compliance requirements. 
Despite the regulatory framework's emphasis on AML compliance, banks 
and other obliged entities do not exercise Know Your Customer (KYC) 
measures or employ Customer Due Diligence (CDD) in any standardized 
manner; thereis no industry-wide approach.  Guidance should come 
from a regulator or from the Ministry of Finance but there are no 
guidance notes for CDD or for TR reporting, and banks follow 
different standars.  The APBEF has not advocated for upgrades to 
ank monitoring and reporting.  As evidenced by the ow statistics 
reported by CENTIF (55 STRs YTD, wth 4 forwarded on to the 
judiciary), there appeas to be a fundamental lack of understanding 
by oliged entities to interpret, dentify, and describe suspicious 
activity. 
 
¶33.  (U) There is a wide variance in training efforts and monitoring 
operations between branches of large international banks and 
Senegalese banks.  Staff in Senegalese branches of large 
international banks receives AML/CFT training through their 
respective headquarters.  However, in Senegalese financial 
institutions (without a parent company) staff have just recently 
begun receiving basic AML/CFT training.  For these banks, more 
in-depth training is necessary. 
 
¶34.  (SBU) As authorities within a subsidiary of a U.S. bank, 
compliance officers at Senegal's Citigroup have had training and 
exercise due diligence measures (including a KYC program) mandated 
by the parent company beyond what is required.  In contrast, the 
local BHS (also with branches in the U.S.) has to date not filed and 
money laundering or terrorist financing STRs.  Although the 
compliance officer for BHS described a fairly thorough CDD and STR 
policy exceeding the legal requirements, disparities still exist. 
BHS personnel received only rudimentary training exclusively from 
CENTIF, but more in-depth training is necessary. 
 
¶35.  (SBU) Although its program is nascent, CENTIF has provided 
outreach to obligated financial sectors.  CENTIF utilizes the 
UNODC's Computer Based Training (CBT) as its basic AML training. 
However, the obliged institutions expressed a need to understand the 
various money laundering typologies.  Of particular concern to the 
FSAT is the apparent widespread confusion over the definition of an 
STR and when and why one should be filed. 
 
TEAM RECOMMENDATIONS - REGULATORS AND BANKS 
------------------------------------------- 
¶36.  (U) The FSAT recommends that the full scope AML/CFT 
examinations be performed at each safety and soundness examination 
 
DAKAR 00000126  002.2 OF 008 
 
 
to determine compliance with rules and regulations and to ascertain 
the condition of the overall AML/CFT program at the institution. 
For supervisory bodies and regulators, experiential training is 
paramount.  BCEAO personnel should receive more specialized training 
incorporating AML/CFT, bank/financial institution examinations, and 
analysis training.  Financial forensics training may also improve 
the efficacy of some agencies.  In order to improve efficacy, 
assistance to help agencies communicate with one another directly 
and share information is key. 
 
¶37.  (U) The FSAT recommends that all individuals responsible for 
filing STRs receive in-depth, specialized AML-CFT training that uses 
live cases and covers methods and procedures, such as how and when 
to file STRs, identification of suspicious activities, and 
collection of money laundering evidence.  Training should be 
conducted to ensure that 100 percent of the staff is up to standard. 
 The Team recommends that local Senegalese banks in particular be 
priority recipients of more specialized AML/CFT training since they 
do not benefit from training through a parent company. 
 
CENTIF, THE FIU 
--------------- 
¶38.  (U) Article 16 of the Uniform Law on Money Laundering requires 
countries to establish a Financial Intelligence Unit (FIU). 
Senegal's FIU, the "Cellule Nationale de Traitement des Informations 
Financiers" or CENTIF, was established in August, 2004 (decree No. 
2004-1150 of 18 August 2004).  The CENTIF is an autonomous agency 
under the authority of the Ministry of Finance, and defines itself 
as an administrative FIU with financial and decision-making 
authority over its own functions.  The CENTIF receives its own 
budget line item and so is not dependent on the Ministry of Finance 
budget.  However, its budget is determined by top administration 
officials.  The CENTIF has five sub-divisions, each headed by a 
deputy director seconded to CENTIF for a three-year term from the 
Ministry of Finance, Ministry of Justice, the Customs Department, 
and the Ministry of Interior.  The BCEAO also has a representative 
within the leadership of the CENTIF.  There are approximately 26 
employees in the CENTIF, incorporating financial, investigative, 
accounting, legal, and computer expertise.  France is reportedly 
sponsoring the CENTIF for membership to the Toronto-based Egmont 
Group. 
 
¶39.  (U) The CENTIF has a mandate to receive, analyze, and process 
financial intelligence (although not necessarily to disseminate it). 
 Once an STR is received, CENTIF is required to provide confirmation 
of receipt.  Incoming STRs are logged by the administrative staff 
and given to the analysis unit to ensure that all information is 
provided correctly by the reporting institutions, it is then 
uploaded to the database.  The Secretary General then determines if 
the case warrants further investigation.  If so, the case is sent to 
the Administrative and Financial Investigations Division for further 
study. 
 
¶40.  (SBU) The spokes of law enforcement feed into the CENTIF hub, 
but information does not pass back to law enforcement.  Once the 
investigation is completed, a report goes to the Deputy Director for 
International Relations and Judicial Matters for a judicial opinion. 
 Based on his/her legal opinion, the case is either sent directly to 
an Examination Committee, or the case is held until further 
information is received.  If the Committee finds that the case has 
merit, the report is submitted to the prosecutor, who must 
immediately pass it to an investigating judge.  After CENTIF 
forwards the case to the investigative judge, there is no assurance 
the case will be pursued or that law enforcement entities and their 
investigations will benefit from the information that has been 
developed. 
 
¶41.  (SBU) The CENTIF receives a fairly low number of STRs, but they 
have increased since its March 2005 inception.  That year, the unit 
received 11 STRs, three of which were forwarded to the investigative 
judge.  In 2006, CENTIF received 60 STRs, eight of which were 
forwarded to the investigative judge.  As of early November 2007, 
CENTIF reports that it has received 55 STRs, but only four have been 
forwarded beyond CENTIF.  There are currently 22 cases pending 
judicial action.  According to Citigroup, which sent a case to the 
 
DAKAR 00000126  003.2 OF 008 
 
 
CENTIF last year, and BHS, which has filed 30-40 STRs so far this 
year, the FIU acknowledges when an STR is received; however, the 
banks do not learn of the fate of the reports. 
 
TEAM RECOMMENDATIONS - THE CENTIF 
--------------------------------- 
¶42.  (SBU) Senegal's FIU has an adequate framework, but the CENTIF 
faces a number of hurdles in its efforts to combat money laundering 
and, once legislation is passed, terrorist financing.  A more 
in-depth assessment of the FIU's actual operations and effectiveness 
would be valuable to determine the CENTIF's largest deficiencies 
before recommending a training continuum.  Any training should 
include basic analysis and specialized AML/CFT training.  The CENTIF 
could also use help in drafting guidance notes for reporting 
institutions and provide outreach to non-bank financial institutions 
and designated non-financial businesses and professions, such as the 
insurance and gaming sectors. 
 
LAW ENFORCEMENT - CUSTOMS AGENCY 
-------------------------------- 
¶43.  (U) The Team met with the Customs Agency, the Senegalese Tax 
Authority, and the Ministry of Interior, the main agencies charged 
with financial crime investigations.  The Customs Agency has two 
main missions and employs inspectors, analysts, and investigators. 
Its primary task is as a revenue agency, with most funds coming from 
duties associated with imported goods.  In 2007, forty seven percent 
of Senegal's budget was generated from Customs duties. 
 
¶44.  (SBU) As a secondary mission, Customs controls all persons and 
goods entering and exiting Senegal, enforces Customs laws and 
regulations, and interdicts contraband being brought into and out of 
the country.  Customs performs interdiction and enforcement 
functions, but does not conduct complex investigations.  Rather, the 
agency provides technical assistance regarding Customs-related 
investigations to other investigative entities such as the 
gendarmerie and Ministry of Interior.  Customs works with, and has a 
correspondent assigned to, the CENTIF.  The relationship with CENTIF 
appears solid, although as of November 2007, Customs had only filed 
three STRs. 
 
¶45.  (SBU) Customs lacks a computer database to facilitate or record 
passenger analyses and inspection, although one is being created. 
Inspectors staff passenger processing operations, and specialized 
inspectors provide limited intelligence and investigative support at 
ports of entry (POE).  There are no traditional passenger screening 
methods or automated criminal record and intelligence queries. 
Records are maintained solely as paper declarations completed by 
passengers.  Inspections are performed on a subjective basis. 
Senegal's land borders are typically not patrolled by Customs 
officers. 
 
¶46.  (SBU) Senegal has reporting requirements for inbound and 
outbound currency exceeding CFA 6 million (approximately USD 
14,000), but travelers are expected to self-declare if they are 
carrying such funds.   The Immigration/Customs forms required of 
arriving passengers at the Dakar airport do not include declarations 
regarding currency or monetary instruments.  Officials advised that 
a separate currency reporting form does exist and is to be completed 
at POE, but it is incumbent upon the traveler to request the 
relevant document from a Customs Officer and voluntarily disclose 
the currency.  By law, inbound currency must be deposited at a 
financial institution within one week of entry into Senegal.  This 
not only leaves a week without controls, but it also shifts the 
burden from law enforcement to financial institutions and their 
reporting requirements.  Therefore, it is likely that significant 
amounts of currency are not disclosed, either due to lack of 
awareness of the requirement or as a result of lax enforcement. 
 
¶47.  (U) Inspection operations for inbound cargo use an automated, 
computer-based targeting system with a risk-based assessment program 
targeting specific criteria, indicating that Senegal is able to 
competently identify and interdict suspect importations.  The 
seaport operation at Dakar is managed in accordance with the 
enforcement strategy of the agency and reflects its primary mission: 
 to identify Customs fraud which would result in non-payment of 
 
DAKAR 00000126  004.2 OF 008 
 
 
duties. 
 
¶48.  (U) Because inspections focus on revenue-generating imports, no 
system exists for assessing exported cargo.  In addition to 
smuggling, the lack of oversight allows for trade-based money 
laundering (TBML).  Customs officials acknowledge that a computer 
system could easily be modeled on the inbound targeting system and 
implemented with only slight modifications. 
 
¶49.  (U) The Ministry of Finance tracks proceeds of exports.  As 
with currency importers, exporters also must open a bank account to 
handle export financial transactions.  It is then incumbent upon the 
bank to decide to file an STR.  However, compliance with the 
suspicious transaction reporting requirement is weak.  Again, as 
with importation of currency, this places the burden of identifying 
possible fraud schemes and TBML activities from law enforcement onto 
regulators -- from Customs onto entities with completely different 
mandates. 
 
¶50.  (U) Ideally, customs should collect all shipping export 
documents and have access to bank records through a clear legal 
process.  The development and implementation of a computerized 
tracking/targeting system and intelligence database for both 
travelers and for outbound cargo is critical.  A system modeled 
after its existing inbound computer based targeting system would 
accomplish this. 
 
LAW ENFORCEMENT - SENEGAL TAX AUTHORITY (STA) 
--------------------------------------------- 
¶51.  (U) The Senegal Tax Authority (STA) is an agency within the 
Ministry of Finance (MOF) that collects a range of taxes, amounting 
to approximately 30 percent of the government's revenue in 2007. 
The tax code does not address money laundering, and with a mandate 
to levy and collect taxes, STA does not focus on the origin of the 
income.  The STA also administers the land tenure system, which 
oversees all transactions relating to land acquisition and transfer 
of real estate.  It is mandatory for all transactions to be 
registered at STA to obtain legal ownership, and STA imposes a 
transaction tax based on the transaction amount. Non-bank dealings 
comprise by far the majority of such transactions. 
 
¶52.  (U) Agents in the STA's fiscal investigations unit are involved 
in examinations, fiscal activities, and monitoring and 
cross-checking financial transactions.  The STA is authorized to 
obtain bank records and is not subject to bank secrecy laws.  The 
STA also has access to registries of all businesses and NGOs. 
However, the STA's investigations are focused on determining taxable 
income and tax obligations, not to detect terrorist financing or 
money laundering.  The STA collects data beneficial to other 
agencies, but there is not a history of sharing this data.  The STA 
is implementing a new database to improve transparency and better 
organize and manage all taxpayer information and transactions. 
Although there is a legal provision for real property seizure, this 
rarely occurs; when a target discovers his property may be seized by 
STA, he usually settles the tax obligation.  Asset seizures are much 
more common by Customs at the point of importation. 
 
¶53.  (SBU) The CENTIF relies heavily on the STA for non-bank 
information   However, the STA correspondent to CENTIF does not 
analyze intelligence, but simply collects data for CENTIF and 
reports any suspicious activity uncovered during tax investigations. 
 The STA can, however, assist with investigations on behalf of the 
CENTIF.  Upon request, the STA searches its files, conducts 
interviews and record checks, and provides the information to 
CENTIF.  Since 2005, the STA correspondent has worked 19 
CENTIF-directed cases.  Occasionally the CENTIF-directed 
investigations benefit the STA by identifying individuals who may be 
avoiding taxes.  Although the STA does not look for money 
laundering, it has become more aware of it through its relationship 
with CENTIF.  The STA recognizes a need to have a better 
understanding of money laundering.  However, to date the CENTIF has 
only provided two days of generalized training to STA investigators. 
 
 
LAW ENFORCEMENT - MINISTRY OF INTERIOR, DEPARTMENT OF NATIONAL 
 
DAKAR 00000126  005.2 OF 008 
 
 
SECURITY 
--------------------------------------------- -------- 
¶54.  (U) By Law, the Ministry of Interior (MOI) has broad authority 
over people and activities within Senegal.  In 1997, the first legal 
provisions relating to money laundering were written under 
anti-narcotics provisions.  Issues surrounding terrorism and other 
international crime are also addressed by the Judicial Police, the 
Senegalese Gendarmerie, and the Department of Surveillance of 
National Territories (DST). 
 
¶55.  (SBU) The MOI's Narcotics Investigation Bureau can conduct 
investigations related to narcotics trafficking, including 
narcotics-related money laundering, without the permission of the 
Ministry of Justice, the Prosecutor, or another judicial authority. 
Agents can initiate investigations, make arrests, and detain 
suspects prior to opening an official file.  They are authorized to 
contact banks and financial institutions directly for account 
information. 
 
¶56.  (SBU) The MOI maintains a working relationship with the CENTIF, 
but reported some difficulty in completing cases on behalf of the 
CENTIF when the FIU controls the flow of information.  The CENTIF 
periodically requests the MOI to conduct checks of its investigative 
records to determine if the subject of an STR has a prior record. 
MOI has thus far been contacted by CENTIF regarding 80 potential 
money laundering cases. 
 
¶57.  (SBU) With the exception of narcotics-related money laundering, 
the MOI cannot conduct financial investigations independent of 
CENTIF and the Prosecutor/Investigative Judge.  Thus, independently 
derived intelligence must be vetted through CENTIF before an 
investigation can commence, resulting in delays and lost 
opportunities to act on time-sensitive intelligence.  MOI 
investigators opined that prosecutors and judges have scant 
knowledge of money laundering or terrorist financing, and need 
training. 
 
¶58.  (SBU) The MOI, through the Department of National Security 
(DST), examines charitable entities and NGOs working throughout 
Senegal.  NGOs and charities are required to register with several 
different Ministries, including the AT-CPEC, the Ministry of Social 
Affairs, and Ministry of Families, but the MOI has the lead to track 
and investigate these entities.  Ministry officials stated that 
there may soon be legislation permitting further monitoring of NGOs. 
 
 
¶59.  (SBU) The lack of technology-based tools is a hindrance to the 
effectiveness of the MOI.  Criminals frequently have more 
technological resources, and there are few computer experts working 
in the Ministry.  While officials are aware that ill-gotten gains 
could be laundered or could support terrorist financing and criminal 
activity, their flow information is limited to traditional law 
enforcement techniques, including informants.  At the same time, 
investigators are generally lacking the knowledge and skills to 
conduct an effective money laundering investigation resulting in a 
conviction.  Weaknesses include interpreting information, conducting 
complex investigations, and shepherding the case through the legal 
process. 
 
TEAM RECOMMENDATIONS - LAW ENFORCEMENT 
-------------------------------------- 
¶60.  (U) Training for law enforcement should include evidence 
collection, forensics/financial analysis, investigative conduct, 
basic AML/CFT methods and procedures, and case assembly.  Practical, 
exercise-based, multi-disciplinary training for investigators, 
police, prosecutors and judges is important so that each facet of 
the system becomes familiar with the issues and legal challenges of 
the others.  Senegal's Customs service would benefit from specific 
training on basic Bulk Cash Smuggling (BCS) related to passenger 
inspections and cargo.  This course could also involve the agencies 
patrolling land borders between POEs and would bolster enforcement 
efforts at the POEs against laundering via cash couriers.  A basic 
course on targeting outbound cargo for examination could highlight 
strategies for these operations.  Customs, alongside the Ministry of 
Finance (which oversees the financial transactions involving 
 
DAKAR 00000126  006.3 OF 008 
 
 
importations and exportations), would both benefit from training 
addressing TBML.  The STA needs specific fiscal examinations or 
forensic accounting training focusing on income analysis and net 
worth. 
 
JUDICIAL SYSTEM 
--------------- 
¶61.  (SBU) The Ministry of Justice (MOJ) is widely perceived to be a 
key agency, yet the weakest link in Senegal's AML regime.  All 
ministries and organizations visited by the FSAT stated that the MOJ 
had the least knowledge or experience in the AML/CFT area. 
Information on approximately fifty potential cases has been 
transmitted from the CENTIF to the Court of Investigation where they 
are managed by Investigative Judges, however, to date there have 
been no prosecutions or convictions for money laundering.  Absent 
ministerial direction, prosecutors have an administrative role and 
have little involvement with money laundering cases. 
 
¶62.  (SBU) An MOJ magistrate is seconded to CENTIF to act as 
gatekeeper, rendering a legal opinion on cases before the dossier is 
forwarded to the court.  While the predicate offense need not be a 
conviction, it is a necessary element of the money laundering crime, 
and the Investigative Judge must investigate the predicate crime 
that allegedly generated the laundered proceeds.  While the law 
provides for AML cases on any predicate offense, the CENTIF has 
focused on offenses incorporating narcotics, fraud, and 
"contraband."  The CENTIF can also pursue cases it believes derives 
from corruption, graft, or misuse of public funds. 
 
¶63.  (U) Senegal has a fairly comprehensive asset forfeiture regime. 
 Upon a conviction, if the Court determines that the assets were not 
the proceeds of or used in the commission of crime, the money/goods 
are returned; if the assets are determined to have facilitated the 
crime or been the proceeds of the crime, the goods are transferred 
to the Public Treasury; or if the assets are deemed to be hazardous 
materials are destroyed. 
 
TEAM RECOMMENDATIONS - JUDICIAL SYSTEM 
-------------------------------------- 
¶64.  (SBU) The MOJ is cognizant of the importance of a strong 
AML/CFT regime, and there has been some AML training organized by 
the U.S. Embassy and by CENTIF.  In general, however, even skillful 
prosecutors and judges lack the necessary understanding of the 
overall coordinated nature of AML/CFT.  Part of the deficiency is an 
apparent lack of understanding of the complexity and multi-faceted 
nature of money laundering and terrorist financing.  The MOJ has 
excellent candidates for multidisciplinary training based upon 
actual cases and experiences.  Such training would include police 
and gendarmes, as well as prosecutors and judges.  Coordinated 
workshops requiring police, gendarmerie, judges, prosecutors and 
CENTIF analysts to work together would result in better 
understanding of each office's responsibilities and lead to better 
coordination among all. 
 
OTHER ENTITIES 
-------------- 
¶65.  (U) The FSAT also met with a number of governmental and 
extra-governmental organizations throughout the week whose missions 
were indirectly related to AML/CFT:  the Inspector General of the 
State (IG), the Anticorruption Commission, the Forum Civil (a local 
affiliate of Transparency International), and the local office of 
the U.N Office for Drugs and Crime (UNODC).  These organizations are 
occupied mainly with corruption issues, with the exception of UNODC, 
which also has AML/CFT mandates. 
 
¶66.  (U) The IG, under Presidential authority, monitors the 
activities and finances of all government agencies and 
administrative services, and is designated to conduct reviews of 
bank accounts of government officials, and investigate matters of 
waste, fraud and abuse.  Investigative missions are initiated at the 
request of the President, who may then accept the findings and 
approve further investigation or refer the matter to the judicial 
authority for action, or terminate the matter. 
 
¶67.  (U) The IG is more concerned with corruption and embezzlement 
 
DAKAR 00000126  007 OF 008 
 
 
than with money laundering or terrorist financing, although they 
recognize parallels.  Senegal's IG interacts with IGs in Canada, 
Djibouti and the European Union, as well as the African Forum of 
IGs, whose mission statement is to promote good governance and 
transparency.  An information sharing agreement with the IGs of the 
EU allows requests for the collection and sharing of information in 
a foreign jurisdiction. 
 
¶68.  (U) Senegal's Anticorruption Commission was established by 
decree in March 2004.  Senegal has recently ratified the UN 
Convention Against Corruption and has had an anticorruption law for 
almost five years.  The Commission's members are interdisciplinary, 
appointed by the President, and work without compensation.  The head 
of the Commission is a retired former attorney general.  The 
commission's annual budget is determined by the Presidency, 
significantly limiting its independence and coercive authorities. 
 
¶69.  (U) The Commission's priority has been outreach and 
consciousness-raising.  With guidance from WAEMU, the Commission 
helped draft Senegal's 2007 public procurement law that limits the 
occasion for sole-source contracts and generally requires an open 
and competitive bidding process.  On the investigative side, the 
Commission passes dossiers to CENTIF as the legal authority for 
investigations, and may or may not receive information back.  The 
law does not authorize Commission investigators access to bank or 
other personal records, although by law, the Commission has recourse 
to state services to properly conduct its missions. 
 
¶70.  (SBU) The Forum Civil (FC) strongly noted its concern about 
corruption, graft, and the need for good governance measures.  The 
FC also provided input to the new public procurement code and is 
advising on the implementation of new financial disclosure 
regulations for all civil servants and Parliamentary members, a 
measure supported by related African conventions against corruption 
and money laundering.  The FC also involves the press in corruption 
issues and has provided investigative journalism training to one 
hundred journalists.  In general, the FC lauded the CENTIF's broad 
mandate, which allows it to delve into everything from embezzlement 
to violations of regulations for currency exchange. 
 
¶71.  (SBU) The UNODC noted concerns about corruption and frustration 
with the ineffectiveness of the Anticorruption Commission and the 
FC.  Regionally, UNODC has been working with the BCEAO on terrorism 
financing legislation with the hope that it will be approved within 
the next six months.  The UNODC also works with the CENTIF and 
provided its computer-based training modules to the FIU as a 
training aid for obliged entities.  UNODC claimed the largest 
vulnerabilities in Senegal were a lack of inter-agency cooperation 
in investigations on organized crime and corruption and also weak 
implementation of asset forfeiture and recovery. 
 
TRAINING CONCLUSIONS 
-------------------- 
¶72.  (U) Based on its visit, the FSAT recommends the following 
training programs be given priority consideration:  AML/CTF training 
for MOJ personnel, judges and prosecutors; AML/CTF financial 
regulatory training; Financial Investigative Training; enhanced 
training for the CENTIF; and Bulk Cash Smuggling training. 
 
PRESS REACTIONS AND POST COMMENT 
-------------------------------- 
¶73.  (SBU) Post thanks the FSAT for its visit and hard work and 
looks forward to coordinating and supporting important training 
activities that further Senegal's capacity and effectiveness in 
combating money laundering and terrorism financing.  The visit of 
the FSAT generated a bit of inaccurate local press coverage, which 
claimed the FSAT included officials from the NSA, CIA, and 
Transportation Department, and that the goal was to determine if 
Senegal needed to be "more closely monitored." 
 
¶74.  (SBU) Institutionally, Senegal has one of the most advanced 
network of agencies and professionals in the region for addressing 
money laundering and terrorism financing threats.  However, these 
institutions remain heavily influenced by Senegal's political 
leadership through appointments, budget allocations, and control of 
 
DAKAR 00000126  008.2 OF 008 
 
 
interagency coordination (or lack thereof).  By establishing one of 
the first functional FIUs in Africa, Senegal could set a positive 
example for domestic action and international cooperation on AML/CTF 
efforts.  Therefore, in addition to the provision of training and 
technical assistance, Washington agencies should look for 
opportunities to reinforce the message that the CENTIF needs the 
continued commitment from the Presidency and the Finance Ministry to 
be adequately funded, supported by other agencies in its 
investigative efforts, and remain free of political manipulation. 
 
¶75.  (SBU) Washington agencies should also keep in mind that 
corruption, graft, and the misuse of public finances remain 
significant problems in Senegal and threaten the country's economic 
well-being and political stability. 
 
SMITH