The World Bank Report No: ISR12281 Implementation Status & Results Benin Implementation of AML/CFT for Benin (P122775) Public Disclosure Copy Operation Name: Implementation of AML/CFT for Benin (P122775) Project Stage: Implementation Seq.No: 2 Status: ARCHIVED Archive Date: 01-Apr-2014 Country: Benin Approval FY: 2011 Product Line: Institutional Development Fund Region: AFRICA Lending Instrument: Implementing Agency(ies): CENTIF BENIN Key Dates Board Approval Date 16-Jan-2011 Original Closing Date 22-Mar-2014 Planned Mid Term Review Date Last Archived ISR Date 07-Jun-2012 Effectiveness Date 22-Mar-2011 Revised Closing Date 22-Mar-2014 Actual Mid Term Review Date 08-Oct-2013 Project Development Objectives Project Development Objective (from IDF Proposal) The objective of the project is to improve the reporting, analysis, and investigation of suspicious transaction reports (STRs) by the private sector and key Government agencies involved in anti-money laundering and counter-terrorism financing (AML/CFT) in Benin, including the judiciary. This will be achieved by: - reinforcing the operational capacities of the financial intelligence unit (FIU), the Cellule Nationale pour le Traitement des Informations Financières (CENTIF) to analyze suspicious transaction reports (STRs) filed by the private sector; - improving the reporting of STRs by the private sector and - ensuring an adequate handling of money laundering and financial crime cases by the judiciary. Has the Project Development Objective been changed since Board Approval of the Project? Yes No Component(s) Component Name Component Cost REINFORCE THE OPERATIONAL CAPACITIES OF THE CENTIF 175123.00 ENHANCING COMPLIANCE WITH AML/CFT LEGAL OBLIGATIONS 146734.00 Public Disclosure Copy AUDIT 15000.00 STRENGTHENING THE LAW ENFORCEMENT RESPONSE TO AML/CFT 91128.00 Overall Ratings Previous Rating Current Rating Progress towards achievement of PDO Moderately Unsatisfactory Moderately Unsatisfactory Overall Implementation Progress (IP) Moderately Unsatisfactory Satisfactory Overall Risk Rating Low Page 1 of 4 The World Bank Report No: ISR12281 Implementation Status Overview The CENTIF has made strong progress in implementing the activities of this IDF, all the activities under the IDF have been implemented or are currently being finalized. Activities aimed at enhancing AML/CFT compliance in the non-bank financial sector, and non-financial sector have been implemented which should lead to an increase in reporting. The CENTIF has also worked with law enforcement authorities, specialized units in economic and financial crimes, as well as judges and prosecutors to enhance their ability to Public Disclosure Copy investigate, prosecute and adjudicate complex financial cases. However, the CENTIF, who is the cornerstone of the national AML/CFT regimes needs to fully mobilize its resources to accelerate its analysis of suspicious transaction reports (STR), and disseminate those to the public prosecutor. Since 2011 no STR has been sent to the public prosecutor. The CENTIF is currently implementing its new procedural manual for STR analysis and training its new staff. Locations No Location data has been entered Results Indicators Indicator Name Core Unit of Measure Baseline Current End Target Number of Suspicious Transaction Reports Text Value 1 2 10 (STR) filed by the non banks and non-financial Date 15-Mar-2010 21-Oct-2013 27-Jun-2014 Reporting Entities Comments At the time of the supervision the final supervision mission mission, the CENTIF was not for this IDF will take place in playing its role as the driver of June 2014. Receiving 10 new the AML/CFT regime - STRs as a result of the contacts with theprivate capacity buildingactivities sector were discontinued. organized is a reasonable This contact was resumed target. with the preparation of the guidelines for financial and non-financial institutions, which included awareness raising activities and private sector consultations on challenges faced in implementing AML/ Public Disclosure Copy CFTmeasures Number of STRs analyzed by the CENTIF Text Value 24 24 50 Date 15-Mar-2010 21-Oct-2013 27-Jun-2014 Comments Situation of blockage within the final supervision mission CENTIF at the time of the for this IDF will take place in supervision mission. STRs June 2014. CENTIF is were not being analyzed and currently implementing its therefore none was new procedure manual and transmitted to the public has committed to reviewing its Page 2 of 4 The World Bank Report No: ISR12281 prosecutor. An emergency entire STR stock, as well as plan has been developed for analyze new STR received. STR analysis with the implementation of the new Public Disclosure Copy procedure manual of the CENTIF Percentage of participants of the workshops on Text Value 0 0 60 investigation and prosecution of money Date 15-Mar-2010 21-Oct-2013 16-Mar-2015 laundering cases successfully completing a Comments The CENTIF did not organize a test was prepared to be knowledge test this test for the 1st training for taken by magistrates magistrates it organized. participating in the second Feedback from participants training currently being was very positive, but no real organized in Cotonou knowledge test was carried out Data on Financial Performance (as of 10-Feb-2014) Financial Agreement(s) Key Dates Project Ln/Cr/Tf Status Approval Date Signing Date Effectiveness Date Original Closing Date Revised Closing Date P122775 TF-98975 Effective 22-Mar-2011 22-Mar-2011 22-Mar-2011 22-Mar-2014 22-Mar-2014 Disbursements Project Ln/Cr/Tf Status Currency Original Revised Cancelled Disbursed Undisbursed % Disbursed P122775 TF-98975 Effective USD 0.43 0.43 0.00 0.23 0.20 54.00 Disbursement Graph Public Disclosure Copy Page 3 of 4 The World Bank Report No: ISR12281 Public Disclosure Copy Key Decisions Regarding Implementation The CENTIF needs to complete the analysis of its back-logged STRs that have been filed by the private sector by implementing the STR analysis procedure manual developed under this IDF and when necessary, disseminate these to the public prosecutor. The CENTIF will continue training activities for its newly senior appointed staff. Restructuring History There has been no restructuring to date. Related Projects There are no related projects. Public Disclosure Copy Page 4 of 4