Divergent Compliance Pathways in West Africa An Independent Analysis of the June 2025 European AML/CFT High-Risk List Revision

On June 10, 2025, the European Commission updated its "list of high-risk third countries" for combating money laundering and terrorist financing (AML/CFT). This review reveals two contrasting trajectories in West Africa: while Côte d’Ivoire has been newly added to the list, Senegal has been removed in recognition of the substantial reforms it has implemented since 2021.

Context and Scope

The European list—formulated by the Commission and reviewed by both the European Parliament and the Council of Europe—complements and, at times, precedes the evaluations conducted by the Financial Action Task Force (FATF). In October 2024, the FATF had already placed Côte d’Ivoire on its "grey list," whereas Senegal had been subjected to "enhanced monitoring" since 2021. Although Brussels partly follows these classifications, it establishes its own criteria and deadlines, thereby adding an extra layer of pressure on the countries involved.

Developments in Côte d’Ivoire

Despite the adoption of a national action plan and the creation of an inter-ministerial committee, Côte d’Ivoire continues to exhibit significant shortcomings:

• Transparency in Investigations and Bank Transactions: High-risk financial flows are not monitored systematically, and judicial outcomes remain only partially accessible.
• Beneficial Ownership Registers: The absence of a reliable public registry complicates the identification of true corporate owners.
• International Cooperation and Control of the Non-Financial Sector: Many notaries, real estate agents, and lawyers lack comprehensive training on AML/CFT obligations, and information exchanges with foreign counterparts are sporadic.

Consequently, European financial institutions must now enforce enhanced due diligence for transactions involving Côte d’Ivoire. While this measure is regulatory in nature and does not affect development or humanitarian aid programs, it is likely to slow investment flows and increase financing costs.

Reforms in Senegal Leading to Delisting

Under enhanced monitoring since 2021, Senegal has implemented 49 FATF-recommended measures. Key reforms include:

• Strengthening the Penal Framework: Amendments to the Penal Code and the Code of Criminal Procedure now explicitly target the financing of individual terrorism.
• Operationalization of the National Office for the Recovery of Criminal Assets (ONRAC): This institution has been active since 2022, responsible for freezing and confiscating illicit assets.
• Adoption of AML/CFT Legislation: In February 2025, formal AML/CFT laws were passed to clarify the obligations of both financial and non-financial actors.

The removal of Senegal from the high-risk list constitutes a significant boost for its economy—a critical advantage for a country dealing with a public debt exceeding 100% of its GDP. This progress is expected to facilitate smoother and less costly access to international fundraising. However, Dakar remains under close observation, with another FATF evaluation scheduled for February 2026.

Regional Implications and Future Perspectives

The coexistence of the FATF and European lists imposes a dual compliance regime on African states, with sometimes divergent criteria and deadlines. This situation compels states to implement rapid and repeated technical reforms. Senegal’s success offers a valuable model for the West African Economic and Monetary Union (UEMOA) and ECOWAS, whereas Côte d’Ivoire’s challenges serve as a cautionary tale of how delays in meeting reform deadlines can lead to stricter regulatory scrutiny and hamper financial flows. In the long term, priorities for the region must include improving the reliability of public registries, enhancing the transparency of judicial statistics, and strengthening cross-border cooperation.

Independent Analysis from Africa Security Analysis

Our in-depth review of AML/CFT challenges in West Africa reveals two distinct yet interconnected narratives. In Côte d'Ivoire, several systemic weaknesses persist despite ongoing reform efforts. Currently, there is a notable lack of transparency regarding beneficial ownership, compounded by limitations within the Financial Crime Investigation Unit, which remains under-resourced for the effective monitoring of high-risk financial flows. Moreover, key professionals in the non-financial sector—such as notaries, lawyers, and real estate agents—often do not receive the comprehensive training necessary to sufficiently address AML/CFT obligations. These shortcomings contribute to significant vulnerabilities that disrupt the overall integrity of financial transactions and hinder effective international cooperation.

Conversely, in Senegal, extensive reforms since 2021 have markedly improved the operational landscape in combating money laundering and terrorist financing. The nation has advanced its penal framework, established robust mechanisms through bodies like the National Office for the Recovery of Criminal Assets (ONRAC), and clarified obligations across both financial and non-financial sectors. However, our analysis indicates that for Senegal to maintain these gains, it is critical that rigorous investigations continue to be carried out and that the legal framework remains dynamic enough to address emerging challenges, such as those posed by cryptocurrency and digital transactions. This dynamic situation illustrates both the transformative potential of sustained reforms and the continual need for vigilance in an evolving financial regulatory environment.

Taken together, these findings underscore the complex duality facing West African states in their efforts to align with international AML/CFT standards. While Senegal’s progress offers a promising model—demonstrating that comprehensive reform can yield tangible economic and regulatory benefits—Côte d'Ivoire’s experience serves as a cautionary tale on the risks of delayed or incomplete reform measures in maintaining investor confidence and financial stability.

Conclusion

The European Commission’s revision on June 10, 2025, highlights two divergent pathways for West Africa in the realm of AML/CFT. Côte d'Ivoire must accelerate implementation of its reform measures to safeguard its economic appeal, whereas Senegal, having shed its previous high-risk stigma, must now demonstrate that its improvements are sustainable over the long term. Ultimately, the genuine effectiveness of supervisory institutions and transparency in practice will be decisive in restoring investor confidence in the 2026–2027 period.

Africa Security Analysis will continue to monitor these developments and provide further recommendations as necessary to support enhanced compliance and financial integrity across the region.