AMF-UMOA

FINANCIAL MARKETS AUTHORITY OF THE WEST AFRICAN MONETARY UNION

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INSTRUCTION NO. 81 /AMF-UMOA/2025

ON THE ACCOUNT REGISTRATION OF FINAL CLIENTS WITH THE CENTRAL DEPOSITORY / SETTLEMENT BANK OF THE UMOA REGIONAL FINANCIAL MARKET

The Financial Markets Authority of the West African Monetary Union,

Having regard to the Revised Treaty of the West African Monetary Union (UMOA) of July 12, 2019, which entered into force on October 1, 2022, modifying the name of the Regional Council for Public Savings and Financial Markets (CREPMF) to the Financial Markets Authority of the UMOA (AMF-UMOA);

Having regard to the Convention of July 3, 1996 establishing the Regional Council for Public Savings and Financial Markets, particularly its Annex on the composition, organization, functioning, and powers of the Regional Council for Public Savings and Financial Markets;

Having regard to General Regulation No. 001/97 of November 28, 1997 on the organization, functioning, and control of the UMOA Regional Financial Market, as amended in Articles 37 and 136 by the UMOA Council of Ministers in its sessions of March 27, 1998 and September 5, 2005;

Having regard to Decision No. CM/07/2021 UMOA of March 21, 2021 adopting the Uniform Law on stock market infractions in the regional financial market;

Having regard to Directive No. 01/2023/CM/UEMOA of March 31, 2023 on the fight against money laundering, terrorist financing, and proliferation of weapons of mass destruction in the member states of the West African Economic and Monetary Union (UEMOA);

Having regard to Decision No. 04/31/03/2023/CM/UMOA of March 31, 2023 adopting the draft Uniform Law on the fight against money laundering, terrorist financing, and proliferation of weapons of mass destruction in the member states of the West African Economic and Monetary Union (UMOA);

Having regard to Instruction No. 59/2019/AMF-UMOA/REVISED on the fight against money laundering, terrorist financing, and proliferation of weapons of mass destruction among actors in the UMOA Regional Financial Market;

Having regard to Decision No. CM/04/03/2024 of March 28, 2024 by the UMOA Council of Ministers appointing the President of the Financial Markets Authority of the UMOA;

Having regard to the deliberations of the AMF-UMOA during its 107th Ordinary Session, held on March 20, 2025 in Abidjan;

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Instruction No. 81 /AMF-UMOA/2025

ORDERS:

TITLE I: GENERAL PROVISIONS

Article 1: Definitions

For the purposes of this Instruction, the following terms shall mean:

• Regional Financial Market Actor: any natural or legal person authorized to exercise a regulated activity on the financial market or to participate therein by virtue of, inter alia, an authorization or approval issued by the AMF-UMOA;
• Client: any natural or legal person or entity receiving a securities account-keeping financial service;
• Final Client: any entity holding a securities account opened with an Account Keeper;
• Individual Account: a securities account opened in favor of a client;
• DC/BR (Central Depository/Settlement Bank): the central depository and settlement bank;
• Account Registration: the process of recording in a DC/BR register the identity and securities holdings of a client of an Account Keeper;
• Financial Institution: any public or private entity benefiting from an authorization, approval, or accreditation issued by a competent authority, authorized to carry out financial operations and/or provide financial services to its clients. These include banks, finance companies, credit institutions, electronic money institutions, payment institutions, microfinance institutions, insurance companies, Deposit and Consignment Funds (CDC), Management and Intermediation Companies (SGI), Collective Investment Schemes (OPC), OPC Management Companies, and Social Security Organizations (OPS);
• Investor: a natural or legal person who makes or intends to make capital investments on the regional financial market;
• Unique Identification Number or Unique Identifier: a unique number assigned by the DC/BR to every final client registered in its books;
• Without Delay: a period not exceeding two (2) business days;
• Account Keeper: any regional financial market participant authorized, by virtue of an authorization or approval, to register financial assets on behalf of third parties;
• UEMOA: the West African Economic and Monetary Union;
• UMOA: the West African Monetary Union.

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Instruction No. 81 /AMF-UMOA/2025

Article 2: Subject Matter

This Instruction sets out the rules regarding the registration of final clients in the DC/BR registers, complementing their registration in the books of Account Keepers.

Article 3: Scope

This Instruction applies to the DC/BR and Account Keepers.

TITLE II: PROVISIONS RELATING TO THE ACCOUNT REGISTRATION OF FINAL CLIENTS BY ACCOUNT KEEPERS

CHAPTER I: OBLIGATIONS OF THE ACCOUNT KEEPER

Article 4: Identification and verification of the final client's identity

Account Keepers are obligated to identify and verify the identity of their clients, as well as their beneficial owners where applicable, particularly during account opening and the establishment of business relationships, in accordance with the legal and regulatory provisions relating to the Fight against Money Laundering, Terrorist Financing, and Proliferation of Weapons of Mass Destruction (AML/CFT/Proliferation) in the member states of the West African Economic and Monetary Union.

Article 5: Account registration of final clients

Any client other than a financial institution, holding a securities account opened with an Account Keeper may, through said Account Keeper, register in the books of the DC/BR.

Article 6: Mandatory account registration of financial institution final clients

Any Financial Institution holding a securities account opened with an Account Keeper is registered in the books of the DC/BR, through said Account Keeper.

Article 7: Information required for account registration

The account registration of the final client in the DC/BR books is initiated by the Account Keeper, which communicates the following information of the final client:

• identity, namely surname and forenames, date and place of birth;
• identification document references, including the national identity card, passport, and national registration, commercial register, or tax identification number;
• the final client's account number registered with the Account Keeper;
• identity of the beneficial owner, where applicable;

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Instruction No. 81 /AMF-UMOA/2025

• references of the identification documents of the final client and the beneficial owner, where applicable;
• address.

The DC/BR may request any supplementary information it deems necessary prior to the account registration of the final client in its registers.

Article 8: Monitoring of securities portfolio

Account Keepers ensure correspondence between the data in the final client's portfolio held in their books and that appearing in the register maintained by the DC/BR. A reconciliation of individual client accounts must be carried out at least once a month.

CHAPTER II: OBLIGATIONS OF THE DC/BR

Article 9: Establishment of a dedicated platform for account registration of final clients by Account Keepers

The DC/BR makes available to Account Keepers a platform enabling the account registration of final clients in its registers and the linking of accounts to a unique identifier as referred to in Article 11.

The DC/BR's information system must enable Account Keepers to initiate, in a secure manner, operations on individual client accounts.

Article 10: Security, integrity and confidentiality of data

The DC/BR implements effective internal control and risk management measures, including IT risks, to ensure the security, integrity, and confidentiality of data.

These measures are implemented without prejudice to legal and regulatory provisions on personal data protection.

The DC/BR ensures the reliability and resilience of its systems, as well as the implementation of a robust business continuity mechanism in case of major incidents, including cyberattacks, thefts, leaks, or data compromise.

Article 11: Creation of a unique identification number

Based on the information provided by the Account Keeper, the DC/BR assigns to each final client registered in its books a unique identification number.

The unique identification number of a final client is linked to all its accounts opened with different Account Keepers.

A client may hold only one identifier in the DC/BR registers.

The DC/BR links, in its books, the unique identifier to all accounts of the final client declared by Account Keepers.

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Instruction No. 81 /AMF-UMOA/2025

Article 12: Communication of the client's unique identification

The DC/BR communicates to any Account Keeper making a request, the unique identification number of a final client who holds or intends to open a securities account in its books.

To process this request, the Account Keeper provides the DC/BR with the required information, including that referred to in Article 7.

TITLE III: INFORMATION OBLIGATIONS

Article 13: Transmission of information to the final client

The Account Keeper communicates without delay to the final client its unique identification number, as soon as the latter is registered in the DC/BR registers.

It also informs, without delay, the final client of the linking of its account to this identification number.

The Account Keeper retains for a period of ten (10) years from the date of cessation of the relationship with the client, a copy of the documents relating to account registration referred to in Article 7 and to the linking of accounts to an identifier.

Article 14: Transmission of registration certificate to the client

Any final client may, upon request, obtain from the Account Keeper a certificate of their account registration in the DC/BR registers.

Article 15: AMF-UMOA's access to DC/BR information

The DC/BR establishes a secure device enabling the AMF-UMOA to access, for consultation, the securities positions of final clients registered in its books.

Article 16: Transmission of periodic information by Account Keepers to AMF-UMOA

Account Keepers transmit to the AMF-UMOA, within fifteen (15) calendar days following the end of each quarter, the status of their final clients registered in the DC/BR registers, as of the last business day of the quarter.

This status is prepared according to the model defined in the annex to this Instruction.

TITLE IV: TRANSITIONAL, DIVERSE AND FINAL PROVISIONS

Article 17: Transitional provisions

The DC/BR and Account Keepers authorized or approved prior to the effective date of this Instruction have a maximum period of one (01) year, from the date of its signature, to comply with all its provisions.

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Instruction No. 81 /AMF-UMOA/2025

Article 18: Sanctions

Any failure to comply with the obligations provided by this Instruction may, in accordance with prevailing regulations, result in sanctions, including financial, administrative, and disciplinary penalties.

Article 19: Entry into force

This Instruction enters into force as of the date of its signature. It shall be published wherever necessary.

Done in Abidjan, on 05 SEP. 2025

For the Financial Markets Authority of the UMOA, The President

(Signature) Badanam PATOKI

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Instruction No. 81 /AMF-UMOA/2025

Annex: Quarterly Status of Final Clients Registered in the DC/BR

End date of quarter: ................................... Name of Account Keeper: ...................................

Type of client	Number of registered clients	Value of securities portfolio of clients registered in account
		Listed equities	Unlisted equities	Listed bonds	Unlisted bonds	Units or shares of collective investment schemes
Individual clients
Non-financial corporate clients
Financial institution clients
TOTAL