The Inter Governmental Action Group against Money Laundering in West Africa has published Benin’s fifth enhanced follow-up report and technical compliance re-rating. The report re-rates Recommendation 16 on wire transfers and Recommendations 24 and 25 on beneficial ownership transparency of legal persons and legal arrangements to Largely Compliant, reflecting legal and regulatory changes made since Benin’s 2021 mutual evaluation. GIABA states that Benin now has seven FATF Recommendations rated Non-Compliant or Partially Compliant, with no fundamental recommendations remaining, and that the country exited the enhanced follow-up process by decision of the November 2025 Plenary. The re-ratings are tied mainly to Benin’s adoption of AML/CFT/CPF Law No. 2024-01, a 2025 law on associations and foundations, a decree creating a register for those entities, and rules establishing a national beneficial ownership register with the tax administration. For wire transfers, the report finds that Benin now requires originator and beneficiary information for domestic and cross-border transfers, record retention and controls by intermediary and beneficiary institutions. For beneficial ownership, GIABA highlights new mechanisms for collecting, maintaining and making available ownership information for companies, associations, foundations and legal arrangements, as well as improved access for domestic and foreign authorities. Residual deficiencies remain. For Recommendation 16, money or value transfer service providers are not explicitly required to file suspicious transaction reports in each country involved in a suspicious transfer. For Recommendation 24, the report cites unclear responsibility for communicating information to competent authorities, no requirement for proxy directors to disclose who appointed them, and a limited sanctions framework. For Recommendation 25, administrative sanctions are still largely limited to formal notices and their proportionality is not assured. GIABA notes that this follow-up report does not assess the effectiveness of Benin’s AML/CFT system. Benin will be required to provide an update on the status of preparations for its forthcoming third round mutual evaluation.
Inter Governmental Action Group against Money Laundering in West Africa (GIABA)2026-05-01
Inter Governmental Action Group against Money Laundering in West Africa re-rates Benin on three AML CFT standards and records exit from enhanced follow-up
GIABA’s fifth enhanced follow-up report for Benin re-rates Recommendations 16, 24 and 25 to Largely Compliant after reforms on wire transfers and beneficial ownership transparency. The report says Benin has exited enhanced follow-up and now has seven recommendations still rated Non-Compliant or Partially Compliant, with no fundamental recommendations. Remaining gaps include cross-border suspicious transaction reporting by money transfer providers and limited sanctions for beneficial ownership breaches.