KYC Requirements in Cameroon

Cameroon is Central Africa's largest economy and the continent's leading cocoa producer, as well as a significant exporter of timber, oil, and aluminium. As the economic hub of the CEMAC (Communauté Économique et Monétaire de l'Afrique Centrale) zone, Cameroon's financial system underpins cross-border trade across six Central African nations. However, Cameroon's placement on the FATF grey list in October 2023 has introduced heightened compliance obligations for businesses and financial institutions dealing with Cameroonian counterparties.

Cameroon's AML/CFT framework operates at two levels: the regional CEMAC Regulation 01/03 (as revised by Regulation 01/18 in 2018) which applies uniformly across all six CEMAC member states, and national legislation including Law 2003/004 and implementing decrees. The national Financial Intelligence Unit is the Agence Nationale d'Investigation Financière (ANIF), operating under the Ministry of Finance.

Legal and Regulatory Framework

The foundation of Cameroon's AML/CFT regime is the CEMAC Regulation 01/03/CEMAC/UMAC/CM of 4 April 2003, as substantially revised by Regulation 01/18/CEMAC/UMAC/CM of 21 December 2018. This regional regulation establishes harmonised AML/CFT obligations across Cameroon, Central African Republic, Chad, Republic of Congo, Equatorial Guinea, and Gabon. It covers customer due diligence, suspicious transaction reporting, record-keeping, and compliance programme requirements for all accountable institutions operating in the CEMAC zone.

At the national level, Law 2003/004 of 21 April 2003 on the prevention and suppression of money laundering in Cameroon establishes domestic criminal offences and enforcement mechanisms. The Banque des États de l'Afrique Centrale (BEAC) — the CEMAC central bank — issues supplementary prudential instructions for financial institutions, while the COBAC (Commission Bancaire de l'Afrique Centrale) serves as the regional banking supervisor.

ANIF: Cameroon's Financial Intelligence Unit

The Agence Nationale d'Investigation Financière (ANIF) was established by Decree 2005/187 of 31 May 2005 and operates under the authority of the Minister of Finance. ANIF is Cameroon's central financial intelligence body and a member of the Egmont Group of Financial Intelligence Units.

Accountable institutions are required to submit Suspicious Transaction Reports (STRs) to ANIF promptly upon forming a reasonable suspicion that a transaction involves proceeds of crime or terrorist financing. ANIF analyses these reports and disseminates financial intelligence to the DGSN (Direction Générale de la Sûreté Nationale), the Gendarmerie Nationale, and the TCS (Tribunal Criminel Spécial) — Cameroon's specialised anti-corruption court — for investigation and prosecution.

FATF Grey List: Implications for Businesses

Cameroon's inclusion on the FATF grey list in October 2023 has significant practical implications for businesses and financial institutions dealing with Cameroonian counterparties. Under the EU's AML Directive framework, EU financial institutions are required to apply Enhanced Due Diligence (EDD) to all transactions involving entities from FATF-identified high-risk jurisdictions.

For Cameroonian exporters, this means that EU import partners, correspondent banks, and trade finance institutions will require more comprehensive KYC documentation, including source of funds declarations, enhanced beneficial ownership verification, and potentially senior management approval for onboarding. The cost and complexity of correspondent banking relationships for Cameroonian entities has increased materially since October 2023.

Cameroon has committed to an action plan addressing the deficiencies identified in its FATF mutual evaluation. Key areas include strengthening ANIF's operational capacity, improving beneficial ownership transparency, enhancing supervision of DNFBPs, and increasing money laundering prosecutions. Progress against this action plan will determine whether Cameroon is removed from the grey list at a future FATF plenary.

Customer Due Diligence Requirements

Under CEMAC Regulation 01/18, accountable institutions in Cameroon must apply a risk-based approach to CDD. The grey list status means that institutions dealing with Cameroonian counterparties should default to Enhanced Due Diligence unless a documented risk assessment supports a lower classification.

Accountable Institutions and Supervised Sectors

Mobile Money and Digital Payments

Cameroon has one of Central Africa's most developed mobile money ecosystems. MTN Mobile Money and Orange Money are the dominant platforms, both operating under BEAC's payment institution framework with tiered KYC requirements.

Export Sector KYC Obligations

Timber and Forestry (EUDR Compliance)

Cameroon is Africa's largest timber exporter to the EU and is directly in scope of the EU Deforestation Regulation (EUDR), which entered into force in June 2023. The EUDR requires EU importers of timber and timber products to conduct due diligence on their supply chains, demonstrating that products do not originate from deforested land and were produced in compliance with the laws of the country of production.

For Cameroonian timber exporters, EUDR compliance requires a verified legal entity identity — including a current RCCM certificate, NIU, and beneficial ownership declaration — as the foundation of any supply chain due diligence submission. This maps directly onto Gate 1 of the Four Gates Framework. Cameroon's grey list status adds an additional layer of EDD that EU importers must apply to their Cameroonian counterparties.

Cocoa and Agricultural Commodities

Cameroon is the world's fifth-largest cocoa producer and a significant exporter of coffee, rubber, and cotton. Cocoa is also in scope of the EUDR, which covers cocoa, coffee, cattle, soya, palm oil, wood, and derived products. Cameroonian cocoa exporters must maintain documented supply chain traceability and a verified entity identity to access EU markets post-EUDR.

Oil and Gas

Cameroon's petroleum sector, managed through SNH (Société Nationale des Hydrocarbures), exports crude oil and refined products subject to CBAM obligations. EU importers of Cameroonian petroleum products must verify the legal entity identity of their counterparty as part of their CBAM filing obligations. Cameroon's grey list status means that EU importers should apply EDD to their Cameroonian oil sector counterparties.

Four Gates Relevance for Cameroon

For Cameroonian exporters — particularly in timber, cocoa, and oil — the Four Gates Framework provides a structured compliance pathway for EU market access. Gate 1 (KYC Identity) requires the Cameroonian entity to establish a verified legal identity record that includes its NIU, RCCM certificate, beneficial ownership structure, and AML compliance status under CEMAC Regulation 01/18.

Given Cameroon's FATF grey list status, EU counterparties will require more comprehensive Gate 1 documentation than for non-grey-listed jurisdictions. A Forensic Entity Certificate anchored through KYC Registry provides Cameroonian exporters with a machine-readable, independently verifiable identity record that satisfies EU EDD requirements and accelerates the onboarding process with EU financial institutions and trade partners.