Countries/Jurisdictions of Primary Concern - Rwanda
Rwanda is not an offshore or financial center. The Rwandan financial system remains relatively unsophisticated, although the number of electronic fund transfers and credit card transactions is rising. Money transfers by cell phone are becoming common. While the black market for smuggled goods is limited, the smuggling of tin, tantalum, tungsten, and gold from the neighboring Democratic Republic of the Congo generates funds that may be laundered through Rwanda’s financial system. The scope of this smuggling is difficult to quantify.
For additional information focusing on terrorist financing, please refer to the Department of State’s Country Reports on Terrorism, which can be found at: //2009-2017.state.gov/j/ct/rls/crt/
DO FINANCIAL INSTITUTIONS ENGAGE IN CURRENCY TRANSACTIONS RELATED TO INTERNATIONAL NARCOTICS TRAFFICKING THAT INCLUDE SIGNIFICANT AMOUNTS OF US CURRENCY; CURRENCY DERIVED FROM ILLEGAL SALES IN THE U.S.; OR ILLEGAL DRUG SALES THAT OTHERWISE SIGNIFICANTLY AFFECT THE U.S.: NO
CRIMINALIZATION OF MONEY LAUNDERING:
“All serious crimes” approach or “list” approach to predicate crimes: All serious crimes
Are legal persons covered: criminally: YES civilly: YES
KNOW-YOUR-CUSTOMER (KYC) RULES:
Enhanced due diligence procedures for PEPs: Foreign: YES Domestic: YES
KYC covered entities: Banks, private legal practitioners, auditors, real estate agents, high-value traders, casino and lottery owners, mobile network operators, travel agencies, and non-governmental organizations (NGOs)
Number of STRs received and time frame: Not available
Number of CTRs received and time frame: Not applicable
STR covered entities: Banks, private legal practitioners, auditors, real estate agents, high-value traders, casino and lottery owners, travel agencies, and NGOs
MONEY LAUNDERING CRIMINAL PROSECUTIONS/CONVICTIONS:
Prosecutions: 0 in 2013
Convictions: 0 in 2013
RECORDS EXCHANGE MECHANISM:
With U.S.: MLAT: NO Other mechanism: NO
With other governments/jurisdictions: YES
Rwanda is not a member of a FATF-style regional body (FSRB).
ENFORCEMENT AND IMPLEMENTATION ISSUES AND COMMENTS:
The establishment of a financial intelligence unit (FIU) within the Rwanda National Police has improved monitoring of the financial system. This improvement, however, has not yet led to an increase in prosecutions and convictions related to financial crimes. In general, relevant agencies of the Government of Rwanda need further training, resources, and technical expertise to effectively investigate and enforce laws concerning money laundering and terrorism financing.
Under Rwandan law, all foreign currency transactions in excess of $20,000 or its equivalent are documented and reported to the Central Bank. Any transaction of any type in excess of $1 million must be reported as a suspicious transaction. These thresholds should be reviewed to determine if they are appropriate, given the average size of transactions in the Rwandan financial system, and should be adjusted, if necessary.
Rwanda should provide safe harbor protections for its reporting entities, seek to provide training and resources for its competent authorities, ensure its FIU’s ability to operate free of undue influence, and pursue membership in a FSRB.