Question 1

What is the DRC's principal AML/CFT/CPF law?

Accepted Answer

Law No. 22/068 of 27 December 2022 is the principal current statute. It replaced the 2004 AML/CFT law and covers money laundering, terrorist financing and proliferation financing.

Question 2

Who receives suspicious transaction reports?

Accepted Answer

CENAREF, the Cellule nationale des renseignements financiers, receives and analyses STRs. BCC receives separate supervisory reports from financial intermediaries within its scope.

Question 3

When must an STR be filed?

Accepted Answer

Without delay once the reporting person knows, suspects or has reasonable grounds to suspect criminal proceeds or links to ML, TF or PF. Attempted transactions and later information changing the suspicion are included.

Question 4

How is an STR submitted?

Accepted Answer

The law permits written, digital, electronic or telephone transmission to CENAREF, with prompt written confirmation of a telephone report. A public self-service CENAREF portal was not verified, so obtain the current secure operational channel directly from CENAREF.

Question 5

Is every transaction over a fixed amount reported to CENAREF?

Accepted Answer

No universal automatic transaction report should be inferred. Law No. 22/068 refers to a separate Finance Minister threshold for specified cash or e-money funds transmissions, but the current amount and procedure must be verified before automation.

Question 6

What occasional CDD threshold applies to BCC-regulated institutions?

Accepted Answer

BCC Instruction No. 15 modification No. 3 states a trigger above USD 15,000 for the transactions and institutions within its scope, including linked transactions. Suspicion and doubts about identity trigger CDD regardless of amount.

Question 7

What beneficial-owner threshold applies?

Accepted Answer

Law No. 22/068 uses more than 25% direct or indirect capital or voting rights, then control by other means and then the applicable statutory management or legal-representative fallback. Ownership percentage is not the only test.

Question 8

Is the central beneficial-owner register operational?

Accepted Answer

The law requires a GUCE-held register, but an official ITIE-RDC notice from 9 April 2026 described the establishing Justice Ministry order as a draft awaiting adoption and operationalisation. Confirm the current order and filing route before automating submission.

Question 9

Can registry data replace independent KYB?

Accepted Answer

No. Verify legal existence, authority, purpose, directors and every ownership or control layer using reliable evidence, and reconcile any registry discrepancy.

Question 10

What happens when identity cannot be verified?

Accepted Answer

Do not establish or execute the relationship or transaction, or end an existing relationship where required, and assess an STR without tipping off the customer. If further CDD itself would alert a suspected customer, stop and report without delay.

Question 11

What rules apply to PEPs?

Accepted Answer

Identify domestic, foreign and international-organisation PEPs, family and close associates; obtain appropriate approval; establish source of funds and wealth; and apply enhanced monitoring. BCC-covered institutions also notify CENAREF of identified PEPs under Instruction No. 15.

Question 12

How long are AML records kept?

Accepted Answer

Generally 10 years. Identity and relationship records run from closure or relationship end, while transaction and enhanced-review records run from execution. Specified detached intermediary wire information is retained at least five years.

Question 13

What is the cash restriction?

Accepted Answer

Transactions at USD 10,000 equivalent or more generally cannot be settled in cash or bearer instruments, subject to statutory exceptions and BCC derogations. That restriction is not itself a universal STR threshold.

Question 14

When is a cross-border cash declaration required?

Accepted Answer

A traveller entering or leaving the DRC declares cash or bearer negotiable instruments at USD 10,000 equivalent or more at the entry or exit point.

Question 15

What happens on a sanctions match?

Accepted Answer

Freeze covered funds, assets and economic resources without delay and without prior notice, prevent availability or services and notify CENAREF and CONASAFIC under the current procedure. Assess an STR separately.

Question 16

Which sanctions lists should be screened?

Accepted Answer

Use the current UN and national lists disseminated by CONASAFIC, subscribe to its secure alerts and use the Sentinelle platform. Preserve the exact list version and match decision.

Question 17

Are virtual-asset services licensed?

Accepted Answer

Law No. 22/068 places VASPs within the reporting perimeter, but this does not prove a current licensing route. Obtain written confirmation and any required approval before offering exchange, transfer, custody or related services.

Question 18

Do biometrics and foreign cloud hosting require privacy approval?

Accepted Answer

Yes. The Digital Code requires prior authorisation for biometric processing and contemplated foreign transfers unless a specific exception applies. Map purposes, security, DPIA and transfer safeguards and confirm the current APD filing process.

Question 19

How quickly must a personal-data breach be notified?

Accepted Answer

The Digital Code uses 'without delay' for controller notification to the APD and affected person and for a processor's alert to its controller, subject to statutory exceptions for individual communication.

Question 20

Is the DRC on the FATF grey list?

Accepted Answer

Yes, as of 16 July 2026. FATF determined in June 2026 that the DRC had substantially completed its action plan and warranted an on-site assessment, but it remained under increased monitoring pending that assessment.

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Téléchargez la checklist KYC, KYB et AML pour Congo-Kinshasa

Recevez le PDF immédiatement

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Vérifiez une fois. Partout.