Instruction No. 81/AMF-UMOA/2025 on the Registration of End Clients with the Central Depository / Clearing Bank of the UMOA Regional Financial Market

AMF-UMOA
WEST AFRICAN MONETARY UNION FINANCIAL MARKETS AUTHORITY

INSTRUCTION NO. 81 /AMF-UMOA/2025

ON THE REGISTRATION OF END CLIENTS WITH THE CENTRAL DEPOSITORY / CLEARING BANK OF THE UMOA REGIONAL FINANCIAL MARKET

The West African Monetary Union Financial Markets Authority,

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 West African Monetary Union Financial Markets Authority (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 relating to 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 offenses on the regional financial market;

Having regard to Directive No. 01/2023/CM/UEMOA of March 31, 2023 on combating 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 combating 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 combating money laundering, terrorist financing, and proliferation of weapons of mass destruction among actors of the UMOA Regional Financial Market;

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

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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HEREBY DECREES:

TITLE I: GENERAL PROVISIONS

Article 1: Definitions
For the purposes of this Instruction, the following terms are defined as follows:

• Actor of the Regional Financial Market: any natural or legal person authorized to exercise a regulated activity on the financial market or to intervene therein pursuant to, inter alia, an approval or authorization granted by the AMF-UMOA;
• Client: any natural or legal person or entity receiving a securities account keeping service;
• End client: any entity holding a securities account opened with an Account Keeper;
• Individual account: a securities account opened in favor of a client;
• CD/CR: Central Depository/Clearing Bank;
• Registration in account: the process of recording the identity and securities holdings of a client of an Account Keeper in a register of the CD/CR;
• Financial Institution: any public or private entity benefiting from an authorization, approval, or accreditation granted by a competent authority, authorized to carry out financial operations and/or provide financial services to its clients. This includes 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 Undertakings (OPC), OPC Management Companies, and Social Welfare Bodies (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 CD/CR to every end client registered in its books;
• Without delay: a period not exceeding 24 working hours;
• Account Keeper: any participant in the UMOA financial market authorized, pursuant to an approval or authorization, 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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Article 2: Purpose
This Instruction sets out the rules regarding the registration of end clients in the CD/CR registries, supplementing their registration in the books of Account Keepers.

Article 3: Scope of Application
This Instruction applies to the CD/CR and Account Keepers.

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

CHAPTER I: OBLIGATIONS OF THE ACCOUNT KEEPER

Article 4: Identification and verification of the end client's identity
Account Keepers are obligated to identify and verify the identity of their clients and their beneficial owners, where applicable, notably when opening accounts and establishing business relationships, in accordance with the legal and regulatory provisions relating to Combating Money Laundering, Terrorist Financing, and Proliferation of Weapons of Mass Destruction (AML/CFT/Proliferation Financing) in the member states of the West African Economic and Monetary Union.

Article 5: Registration of end clients in accounts
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 CD/CR.

Article 6: Obligation to register financial end clients in accounts
Any Financial Institution holding a securities account opened with an Account Keeper is registered in the CD/CR, through said Account Keeper.

Article 7: Information required for registration in account
The registration of the end client in the books of the CD/CR is initiated by the Account Keeper, which communicates the following information of the end client:

• Identity, namely surname and first names, date and place of birth;
• References of the identification document, notably the identity card, passport, and national registration, recording, commercial register, or tax identification number;
• The end client's account number registered with the Account Keeper;
• Identity of the beneficial owner, where applicable;

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• References of the identification documents of the end client and the beneficial owner, where applicable;
• Address.

The CD/CR may request any additional information it deems necessary prior to registering the end client in its registries.

Article 8: Portfolio monitoring
Account Keepers ensure correspondence between the data of the end client's portfolio held in their books and that appearing in the register kept by the CD/CR. Reconciliation of individual client accounts must be carried out at least once a month.

CHAPTER II: OBLIGATIONS OF THE CD/CR

Article 9: Establishment of a dedicated platform for the registration of end clients by Account Keepers
The CD/CR provides Account Keepers with a platform allowing the registration of end clients in its registries and the linking of accounts to a unique identifier referred to in Article 11. The CD/CR's information system must allow Account Keepers to initiate, securely, operations on the individual accounts of clients.

Article 10: Security, integrity, and confidentiality of data
The CD/CR implements effective internal control and risk management measures, including IT risks, to guarantee the security, integrity, and confidentiality of data. These measures are implemented without prejudice to the legal and regulatory provisions on personal data protection. The CD/CR ensures the reliability and resilience of its systems, as well as the implementation of robust business continuity arrangements in the event of a major incident, notably in case of cyberattacks, theft, leaks, or compromise of data.

Article 11: Creation of a unique identification number
Based on the information provided by the Account Keeper, the CD/CR assigns a unique identification number to each end client registered in its registries.
The unique identification number of an end client is linked to all his/her accounts opened with different Account Keepers.
A client may only have one identifier in the CD/CR registries.
The CD/CR links the unique identifier to all accounts of the end client declared by the Account Keepers in its books.

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Article 12: Communication of the client's unique identification
The CD/CR communicates to any Account Keeper requesting it the unique identification number of an end client who holds or intends to open a securities account in its books. To process this request, the Account Keeper provides the CD/CR with the required information, notably those referred to in Article 7.

TITLE III: INFORMATION OBLIGATIONS

Article 13: Transmission of information to the end client
The Account Keeper communicates without delay to the end client his/her unique identification number, upon registration of the latter in the CD/CR registries. It also informs, without delay, the end client of the linking of his/her 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 the registration in account referred to in Article 7 and to the linking of accounts to an identifier.

Article 14: Transmission of registration certificate to the client
Any end client may, upon request, obtain from the Account Keeper a certificate of his/her registration in the CD/CR registries.

Article 15: Access of the AMF-UMOA to CD/CR information
The CD/CR implements a secure device allowing the AMF-UMOA to access, for consultation, the securities positions of end clients registered in its books.

Article 16: Periodic transmission of information by Account Keepers to the AMF-UMOA
Account Keepers transmit to the AMF-UMOA, within fifteen (15) calendar days following the end of each quarter, the status of their end clients registered in the CD/CR registries, as of the last working 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 CD/CR and Account Keepers approved or authorized before the entry into force 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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Article 18: Sanctions
Any failure to comply with the obligations provided for by this Instruction may, in accordance with current regulations, result in sanctions, notably pecuniary, administrative, and disciplinary.

Article 19: Entry into force
This Instruction enters into force as of the date of its signature.
It will be published wherever necessary.

Done in Abidjan, on SEP. 05, 2025

For the West African Monetary Union
Financial Markets Authority,
The President

Badanam PATOKI

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Annex:
Quarterly situation of end clients registered in the CD/CR

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

Type of client	Number of registered clients	Value of securities portfolio of registered clients
		Listed Shares	Unlisted Shares	Listed Bonds	Unlisted Bonds	Units or Shares of UCITS
Natural Person Clients
Non-Financial Legal Entity Clients
Financial Institution Clients
TOTAL