Circular 05/LBC-FT/2026 on the Sanctions Matrix for Banking Law Establishments Under Regulation 02/2026

BANQUE DE LA REPUBLIQUE DU BURUNDI

CIRCULAR NO. 05/LBC-FT/2026 RELATING TO THE SANCTIONS MATRIX FOR ESTABLISHMENTS SUBJECT TO BANKING LAW, ISSUED PURSUANT TO REGULATION NO. 02/2026 RELATING TO THE COMBAT AGAINST MONEY LAUNDERING AND THE FINANCING OF TERRORISM

The Governor of the Banque de la République du Burundi,

Having regard to Law No. 1/34 of December 2, 2008, establishing the Statutes of the Banque de la République du Burundi;

Having regard to Law No. 1/17 of August 22, 2017, governing banking activities;

Having regard to Law No. 1/07 of May 11, 2018, establishing the National Payment System;

Having regard to Law No. 1/05 of February 27, 2019, governing the Burundi capital market;

Having regard to Law No. 1/08 of March 27, 2025, amending Law No. 1/02 of February 4, 2008, relating to the combat against money laundering and the financing of terrorism, specifically Articles 78 and 79;

Having regard to Regulation No. 02/2026 relating to the combat against money laundering and the financing of terrorism, issued in application of Law No. 1/08 of March 27, 2025, amending Law No. 1/02 of February 4, 2008, relating to the combat against money laundering and the financing of terrorism, specifically Article 21;

Hereby issues:

Article 1: Purpose The purpose of this Circular is to specify the sanctions to be imposed based on the types of breaches regarding violations of legal and regulatory provisions governing banking activities, as well as the procedures to be followed in their application.

Article 2: Scope of Application This Circular applies to establishments subject to banking law as follows:

1. Credit institutions;
2. The National Post Office;
3. Currency exchange offices;
4. Payment institutions;
5. Financing and/or guarantee funds;
6. Microfinance institutions.

---

Article 3: Types of Sanctions When a subject establishment has infringed upon the provisions of Law No. 1/08 of March 27, 2025, amending Law No. 1/02 of February 4, 2008, relating to the combat against money laundering and the financing of terrorism, the Central Bank may apply one or more of the measures or sanctions provided for in Article 79 of the aforementioned law.

The sanctions are of two types, namely administrative sanctions and pecuniary sanctions.

Article 4: Categorization of Breaches Breaches are subdivided into the following categories:

1. Breaches related to vigilance obligations;
2. Breaches related to document retention obligations;
3. Breaches related to internal organization obligations;
4. Breaches related to the obligation to report suspicious transactions;
5. Breaches related to the obligation to transmit information.

Article 5: Gradual Application of Sanctions In order to ensure a gradual application of sanctions and to give subject establishments the opportunity to take appropriate corrective measures, the Central Bank follows the following procedure:

1. Upon finding an infringement or breach, the Central Bank sends a letter to the establishment concerned, recommending that it regularize the situation;
2. In the case of a breach or infringement requiring immediate regularization where the explanation provided is not deemed satisfactory, the Central Bank issues an injunction with a deadline beyond which a sanction may be imposed;
3. In the case of a breach or infringement requiring complex corrective measures, the Central Bank may grant the establishment a deadline for their implementation. Otherwise, the Central Bank issues an injunction with a deadline beyond which a sanction may be imposed.

In the case of breaches or infringements involving a Manager or Administrator, the same procedure is applied.

Article 6: Gradual Application of Sanctions Notwithstanding the procedure described in Article 5, for cases deemed serious by the Central Bank, the latter may directly apply the sanctions provided for in the matrix, after a request for explanation whose response is not satisfactory.

Article 7: Payment Procedures for Penalties In the case of penalties or pecuniary sanctions, the corresponding sums are immediately paid by automatic debit from the subject establishment's account held at the Central Bank.

Article 8: Entry into Force This Circular enters into force on the day of its publication on the website of the Banque de la République du Burundi and in the Official Bulletin of Burundi.

Done in Bujumbura, on 30/4/2026 Edouard Normand BIGENDAKO Governor.

---

ANNEX TO CIRCULAR NO. 05/LBC-FT/2026 RELATING TO THE SANCTIONS MATRIX FOR ESTABLISHMENTS SUBJECT TO BANKING LAW ISSUED PURSUANT TO REGULATION NO. 02/2026 RELATING TO THE COMBAT AGAINST MONEY LAUNDERING AND THE FINANCING OF TERRORISM

	BREACHES	SANCTIONS
I.	Breaches related to vigilance obligations
1.	Absence or insufficiency of identification and verification of the identity of clients and beneficial owners.	Administrative sanctions against managers and/or pecuniary sanction of BIF 5,000,000.
2.	Absence of identification of occasional clients as well as, where applicable, the beneficial owner of the transaction.	Administrative sanctions against managers and/or pecuniary sanction of BIF 5,000,000.
3.	Absence/insufficiency of identification and assessment of money laundering and terrorist financing risks to which subject establishments are exposed.	Administrative sanctions against managers and/or pecuniary sanction of BIF 10,000,000.
4.	Failure to update client information throughout the business relationship.	Administrative sanctions against managers and/or pecuniary sanction of BIF 5,000,000.
5.	Failure to detect Politically Exposed Persons (PEPs) or lack of enhanced vigilance towards them.	Administrative sanctions against managers and/or pecuniary sanction of BIF 15,000,000.

---

II.	Breaches related to document retention obligations
1.	Failure to retain documents or records related to KYC and Due Diligence obligations and others (destruction, removal, loss, ...)	Administrative sanctions against managers and/or pecuniary sanction of BIF 5,000,000.
2.	Failure to retain identity documents and transaction records during legal deadlines.	Administrative sanctions against managers and/or pecuniary sanction of BIF 10,000,000.
III.	Breaches related to internal organization obligations
1.	Absence of the entity responsible for AML/CFT	Administrative sanctions against managers and/or pecuniary sanction of BIF 10,000,000.
2.	Failure to designate the person responsible for implementing the anti-money laundering and counter-terrorist financing framework.	Administrative sanctions against managers and/or pecuniary sanction of BIF 10,000,000.
3.	Absence of policies, procedures, and controls to effectively mitigate and manage ML/FT risks.	Administrative sanctions against managers and/or pecuniary sanction of BIF 5,000,000.
4.	Absence of harmonized policies for the prevention of money laundering and terrorist financing.	Administrative sanctions against managers and/or pecuniary sanction of BIF 5,000,000.
5.	Absence of a framework for freezing and targeted financial sanctions.	Administrative sanctions against managers and/or pecuniary sanction of BIF 15,000,000.
6.	Absence of regular training for staff on AML/CFT.	Administrative sanctions against managers and/or pecuniary sanction of BIF 10,000,000.

---

IV.	Breaches related to the obligation to report suspicious transactions
1.	Failure to report to the CNRF significant transactions, suspicious operations, sums of illicit origin, or transactions with questionable economic justification.	Administrative sanctions against managers and/or pecuniary sanction of BIF 20,000,000.
2.	Failure to respect the obligation of confidentiality materialized by warning clients when information regarding a suspicious transaction concerning them is communicated to the CNRF.	Administrative sanctions against managers and/or pecuniary sanction of BIF 10,000,000.
V.	Breaches related to the obligation to transmit information
1.	Failure to transmit the report on the implementation of the entire anti-money laundering framework to the BRB.	Administrative sanctions against managers and/or pecuniary sanction of BIF 10,000,000.
2.	Late transmission of the control report, the periodic internal control report to the BRB.	Administrative sanctions against managers and/or pecuniary sanction of BIF 5,000,000.