For some time now, the Senegalese media have been increasingly reporting on CENTIF reports submitted to the courts, particularly those involving Politically Exposed Persons (PEPs). Some columnists do not hesitate to dissect them, or even "read" them on set, thus disseminating sensitive information—often raw—to an audience that is not always familiar with the precise role of this institution. As a banking compliance expert, specializing in the fight against financial crime in Africa with more than thirteen years of regional experience, I wish to warn of the systemic risks of such an approach. My goal is to be the voice of banks and Compliance Officers, who are often faced with managing unverified or erroneous data, and to provide documented insight into these complex issues.

1. CENTIF: role, composition and challenges

The National Financial Information Processing Unit (CENTIF), in its capacity as a financial intelligence unit (FIU), is an independent administrative structure under the authority of the Ministry of Finance. Created under Uniform Law No. 2004-09 of February 6, 2004, it reflects the desire of the WAEMU states to combat financial crime and money laundering. Its action is now part of the legal framework of Senegalese Law No. 2024-08 of February 14, 2024, relating to the fight against money laundering and the financing of terrorism.

Composed of experts from the Ministries of Finance and Justice, the BCEAO, and other supervisory institutions, the CENTIF's mission is to centralize and analyze Suspicious Transaction Reports (STRs) submitted by "subjects." Under the regulations, those subject to the regulations cover 24 professional categories. These include not only banks (28 institutions) and decentralized financial services (128 structures), but also notaries, real estate agents, casinos, and even precious metals dealers.

The role of CENTIF is crucial in a context where Illicit Financial Flows (IFF) represent a major challenge. The latest GIABA 2024 report estimates that these flows in Senegal amount to more than 95 billion FCFA, originating in particular from the extractive sector, corruption, tax fraud, and false customs declarations.

It is essential to clarify that the CENTIF is not a supervisory authority like the IGF (General Inspectorate of Finance) or the IGE (General State Inspectorate). In accordance with Article 64 of the Uniform Law, it does not conduct contradictory audits. Its mission is to receive, process, and analyze financial flows to verify their legality—that is, to determine the origin, destination, and economic justification of atypical transactions—and, where appropriate, to inform the judicial authority. This activity is illustrated by its 2024 annual report, which reports the processing of 928 suspicious transaction reports, resulting in the transmission of 46 STRs to the courts, a rate of 4.95%. These figures confirm that suspicious transaction reports, far from being systematic, only concern a very limited number of transactions.

Finally, in accordance with the Egmont Group charter, CENTIF exchanges information with foreign Financial Intelligence Units (FIUs), such as TRACFIN in France. These exchanges, governed by the principles of reciprocity and confidentiality, ensure data security while strengthening international cooperation.

2. Banks: between customer protection and legal obligations

Senegalese banks, which in 2024 held total assets of 13,940.04 billion FCFA according to the BCEAO, have a fundamental mission: to receive household savings, finance the economy, while protecting and advising their clients.

As such, they play an important role in the fight against financial crime, with an obligation to monitor transactions and strengthened controls on PEPs. The management of this clientele, which attracts particular media interest, is carried out with discernment, both from a commercial and risk management perspective, with a constant concern to protect the interests of these sensitive clients. This management applies to the three spheres of PEPs: i) by status (persons holding or having held important public functions), ii) by the circle of influence (persons directly linked to PEPs by their status) and iii) by the family circle (first-degree family members of PEPs i) and ii) ). Thus, the fight against the misappropriation of public funds does not only concern public office holders, but can also involve their immediate entourage.

Ultimately, it's important to remember that the primary goal of banks is not to denounce, but to advise and protect their customers. This is why they take all necessary steps to protect their customers' reputations, as any deterioration in their reputation undoubtedly affects them as well.

3. Compliance Officers: a stimulating, stressful and little-known role

The Compliance Officer, whose duties are specified in Articles 12 to 14 of the Uniform Law, ensures compliance with legal and regulatory standards under often difficult conditions. The latest survey by the Association of Compliance Officers of French-speaking Africa (published in June 2024) reveals the scale of this task: a professional handles an average of 812 alerts per month, resulting in only 4.8 declarations to CENTIF after a thorough investigation. This figure, which corroborates the low transmission rate mentioned above, is in total contradiction with the stigmatization of banks observed in the media.

This excessive media coverage, which often mentions the names of banking institutions, places these professionals in an untenable situation. Turnover in this profession is now reaching worrying levels, primarily due to the stress and reputational risks it faces. Data also shows that the majority of Compliance Officers surveyed consider media pressure to be their primary source of professional stress.

Ultimately, it is imperative that journalists covering CENTIF issues adopt a responsible approach, avoiding generating widespread distrust of the banking system, which would only weaken the Senegalese economy. Banks, which significantly contribute to private investment and a significant contribution to the national GDP, deserve balanced media coverage.

Compliance officers, whose thankless but vital mission is to protect the integrity of our financial system, demand that their actions be understood rather than stigmatized. Media coverage must prioritize in-depth analysis over sensationalist revelations, while preserving the necessary confidentiality of proceedings. Transparency, essential as it is, must be combined with caution to maintain the delicate balance between justice and financial stability, between the right to information and the protection of economic actors.

Abdou KEBE,

Banking Compliance Expert in Africa

Specializing in the fight against financial crime

Kebe.abdou@gmail.com