Instruction No. GR/2024 on Thresholds for Reporting Cash, Transfer and Mobile Banking Transactions to the Mauritanian Financial Investigations Unit

Islamic Republic of Mauritania

Central Bank of Mauritania
Nouakchott, December 31, 2024

Instruction No. GR/2024 Setting the Threshold for Reporting Cash, Transfer and Mobile Banking Transactions to the Mauritanian Financial Investigations Unit

The Governor of the Central Bank of Mauritania;

Having regard to Law No. 73.118 of May 30, 1973 establishing the Central Bank of Mauritania; Having regard to Law No. 2018-034 of August 8, 2018 on the statutes of the Central Bank of Mauritania; Having regard to Law No. 2018-036 bis of August 16, 2018 on the regulation of credit institutions; Having regard to Law No. 2019-017/P.R of February 20, 2019 on the fight against money laundering and terrorist financing; Having regard to Decree No. 2019-197/P.M/M.J implementing Law No. 2019-017/P.R of February 20, 2019 on the fight against money laundering and terrorist financing; Having regard to Decree No. 2019-198 on the National Committee for the Fight against Money Laundering and the Financial Investigations Unit; Having regard to Decree No. 041/2022 dated March 31, 2022 appointing the Governor of the Central Bank of Mauritania; Having regard to Instruction No. 14/GR/2008 of July 29, 2008 recalling the obligation of vigilance and customer due diligence in the banking and financial sector and setting out the procedures for suspicious transaction reporting as well as the relevant forms; Having regard to the deliberations of the Prudential Resolution and Financial Stability Council dated December 27, 2024,

HEREBY DECIDES:

Article 1: Object
This Instruction aims to set the thresholds from which financial institutions subject to the provisions of the law on the fight against money laundering and terrorist financing (hereinafter AML/CFT) are required to report without delay to the Mauritanian Financial Investigations Unit (UMEF) any transaction or attempted transaction exceeding the thresholds defined below, or when it presents a suspicious character.

Article 2: Thresholds applicable to financial transactions:

1. Cash transactions:
   Any cash transaction (deposit and withdrawal) equal to or exceeding 1,000,000 MRU must be subject to a suspicious transaction report if not supported by appropriate documentation.

2. Transfers via electronic wallets (wallets):
   Money transfers via electronic wallets equal to or exceeding 2,000,000 MRU must be monitored and reported if inconsistencies or suspicions are detected. A report is mandatory in the case of split transactions (multiple transfers aimed at circumventing the threshold).

3. Bank transfers:
   National and international bank transfers equal to or exceeding 2,000,000 MRU must be reported in case of doubt regarding their origin or purpose.

Article 3: Reporting procedures:
Any transaction exceeding the defined thresholds or presenting suspicious characteristics must be reported to UMEF in writing within 2 business days after its detection, using the suspicious transaction report form attached to this instruction.

Article 4: Due diligence regarding Risk Persons (PEPs): Notwithstanding the provisions of this instruction, any PEP must be subject to enhanced due diligence by financial institutions and a suspicious transaction report in case of doubt regarding the origin of the transaction, regardless of supporting documents provided. Financial institutions must, in this regard, maintain a list of persons subject to the legal obligation to declare their assets. This list must be integrated into the financial institution's information system to ensure automatic verification.

Article 5: Monitoring and prevention:
Financial institutions and other regulated entities must implement systems capable of automatically detecting transactions exceeding these thresholds. Split or repeated transactions aimed at avoiding the fixed thresholds must be reported as suspicious.

Article 6: Confidentiality and protection: Reports made within the framework of these thresholds are strictly confidential. Reporting parties acting in good faith are protected against any civil or criminal liability.

Article 7: Sanctions for non-compliance:
Non-compliance with the provisions of this Instruction is subject to sanctions in accordance with Law No. 2019-017/P.R of February 20, 2019 on the fight against money laundering and terrorist financing.

Article 8: Entry into force:
This Instruction enters into force on the date of its signature, and it repeals and replaces any prior and contrary provisions.

Moha Y. [Signature]
Governor

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Islamic Republic of Mauritania
Mauritanian Financial Investigations Unit
Suspicious Transaction Report Form

1. Date of submission:
2. The reporting party:
   2.1 Name of the entity:
   2.2 Type of entity:
   2.3 Address of the entity:
   The Branch/agency where the suspicion arose:
   2.4 Branch/agency code:
   2.5 Address of the Branch/agency:
   2.6 Name of the supervisory authority:
   2.7 Registration number with the supervisory authority:
3. Person responsible for the report:
   3.1 Name:
   3.2 Position/Title:
   3.3 Telephone number(s):
   3.4 Email:
   Suspicious transaction report
   4.1 Type of report:
   4.2 Report number:
   4.3 Date of report:
   Type of suspicion:
   Suspected natural person
   Information on the suspected natural person:
   5.1.1 Full name:
   5.1.2 Nationality:
   5.1.3 ID document type:
   5.1.4 ID issuing authority:
   5.1.5 ID expiry date:
   5.1.6 Date of birth:
   5.1.7 Place of birth:
   5.1.8 Sex:
   5.1.9 Marital status:
   5.1.10 Workplace name:
   5.1.11 Employer name:
   5.1.12 Employer address:
   5.1.13 Employer postal code:
   5.1.14 Employer telephone number:
   5.1.15 Nature of employer's activity:
   5.1.16 Annual income:
   5.1.17 Annual income source:
   Partner name for joint accounts:
   5.1.18 Partner address for joint accounts:
   Data on the natural person exercising a profession:
   5.2.1 Profession type:
   5.2.2 Professional registration number:
   5.2.3 Workplace address:
   5.2.4 Workplace email:
   5.2.5 Workplace PO Box:
   5.2.6 Workplace telephone number:
   5.2.7 Nature of relationship with the suspect:
   5.2.8 Is the relationship still active?:
   Data on the beneficial owner of the suspected natural person (if different from the account holder subject to suspicion):
   5.3.1 Name:
   5.3.2 Nationality:
   5.3.3 ID document type:
   5.3.4 Identification number:
   5.3.5 Relationship of the beneficial owner with the suspect:
   Suspected legal entity
   6.1 Information on the suspected legal entity:
   6.1.1 Trade name:
   6.1.2 Legal form:
   6.1.3 Commercial registration number:
   6.1.4 Date of establishment:
   6.1.5 Share capital:
   6.1.6 Activity description according to the commercial register:
   6.1.7 Address:
   6.1.8 Email:
   6.1.9 Postal code:
   6.1.10 Telephone number(s):
   6.1.11 Fax number(s):
   6.1.12 Names and roles of senior management:
   6.1.13 Persons authorized to act on behalf of the legal entity:
   6.1.14 Date of commencement of relationship with the legal entity:
   6.2 Data on the beneficial owner of the suspected legal entity:
   6.2.1 Name:
   6.2.2 Nationality:
   6.2.3 Identifier type:
   6.2.4 Identification number:
   6.2.5 Relationship of the beneficial owner with the suspected legal entity:
4. Other persons related to the transaction:
   Suspected Person (Related Suspected Person)
   7.1 Name:
   7.1.2 Identification document (To be mentioned):
   7.1.3 Identification document (To be mentioned):
   7.1.4 Link with the suspicious transaction:
   Relationship of the notified entity with the suspects:
   7.1 Name of the suspect:
   7.2 Type of relationship:
   Details of the suspicious transaction:
   9.1 Name of the suspect:
   9.2 Measures taken:
   10 Details of the suspicious transaction:
   10.1 Date:
   10.2 Transaction type:
   10.3 Indications and reasons for suspicion:
   11 Account information: (to be completed for each account separately)
   11.1 Account type:
   11.2 Account opening date:
   11.3 Branch that opened the account:
   11.4 Account number:
   11.5 Purpose of the transaction on the account:
   11.6 Account currency:
   11.7 Account balance:
   11.8 As of:
   11.9 Account review period: From ... To ...
   Total credit movement on the account during the review period: Total debit movement on the account during the review period:
   11.10 Highest credit balance on the account over the last three years:
   11.11 Related accounts (To be cited):
5. The Bank is required to provide the Financial Intelligence Unit with the following elements:
   12.1 Client identification documents and account opening form:
   12.2 Due diligence and client identification documents for the suspected person:
   12.3 Other documents obtained during account opening or establishment of a business relationship:
   12.4 Account statement:
   12.5 Copies of financial transactions:
   12.6 Any other document supporting the suspicious transaction (linked to the suspicious transaction):