The verdict in three sentences
A commercial bank with 90,000 customers in Libreville must screen 100 % of transfers against sanctions lists, detect unusual activity and keep a full trail of every suspicious transaction report sent to the national financial intelligence unit (ANIF), under COBAC supervision. International suites cost, as a 2026 order of magnitude, EUR 80,000 to 250,000 (about FCFA 52 to 164 million) before integration, while custom software connected to the core banking system falls in Kolonell's complex range of FCFA 7,000,000 to 15,000,000+, with the final amount set in the quote. The real issue is not the tool alone but the quality of the scenarios and the traceability of decisions, which COBAC inspectors review case by case.
What examiners expect from an AML/CFT framework in the CEMAC zone
The reference framework is the 2016 CEMAC regulation on anti-money laundering and counter-terrorist financing, supplemented by COBAC rules and FATF recommendations relayed by GABAC, the regional body. In practice, inspections test four capabilities: know the customer, screen, monitor, report.
| Requirement | What the tool must do | Indicator checked by examiners |
|---|---|---|
| Know your customer (KYC) | Risk profile at onboarding, periodic review by risk level | Share of up-to-date files, target above 95 % |
| Sanctions screening | Check 100 % of inbound and outbound transfers against UN, EU, OFAC and national lists | Alert handling time, false positive rate |
| Politically exposed persons | Identification and senior sign-off on the relationship | Number of PEPs identified and reviewed in the year |
| Transaction monitoring | Configurable scenarios (structuring, cash, high-risk countries) | Alerts closed within 30 days |
| Suspicious transaction reports | Time-stamped case, documented decision, filing to ANIF | Time from alert to report |
| Audit trail | Immutable history of every decision | Records kept for 10 years |
The most common weakness in banks across the sub-region is the audit trail: alerts closed by email or in spreadsheets with no written rationale. That is exactly what a dedicated tool fixes.
International suite or custom build: the figures
Large compliance vendors offer proven scenario libraries, but their total cost and their integration with core banking systems used in Central Africa weigh heavily.
| Criterion | International suite | Kolonell custom build |
|---|---|---|
| Licence or investment | EUR 80,000 to 250,000, or FCFA 52 to 164 M (2026 order of magnitude) | Complex application: FCFA 7,000,000 to 15,000,000+ (EUR 10,670 to 22,870+), in the quote |
| Annual maintenance | 18 to 22 % of licence | Premium maintenance FCFA 120,000 a month |
| Commercial PEP data | Often included or optional | Third-party subscription, roughly FCFA 5 to 20 M a year |
| Core banking integration | 3 to 6 months, consultants billed in EUR | Connectors built on your core and SWIFT formats |
| Total timeline | 9 to 15 months | 6 to 9 months |
| Scenario tuning | Rich but complex, often outsourced | Scenarios written with your compliance team |
| Language and local formats | Interface sometimes English only | French interface, ANIF formats built in |
Custom only makes sense if the bank commits to solid governance: a compliance head who signs off the rules, an IT team that maintains the feeds, and an annual review of scenario effectiveness. Official sanctions lists (UN, EU, OFAC) are public and free; PEP and adverse media databases remain commercial subscriptions to budget separately.
Architecture and a 6 to 9 month timeline
| Phase | Duration | Deliverable |
|---|---|---|
| Regulatory discovery | 4 weeks | Risk map, priority scenarios |
| Connectors | 6 to 8 weeks | Core banking feeds, SWIFT MT103 and domestic formats |
| Screening engine | 6 weeks | Fuzzy name matching, transliteration, adjustable thresholds |
| Monitoring and case management | 8 weeks | Scenarios, alert handling, suspicion files |
| Testing with compliance | 4 to 6 weeks | Back-testing on 12 months of history, false positive measurement |
| Go live | 2 weeks | Cutover, training for 6 to 10 analysts |
Screening calibration is decisive. A threshold that is too low can generate 3,000 alerts a month on 90,000 customers and swamp the team; too high and real matches slip through. Back-testing finds the balance before production.
Mini case study
Mr Ndong, head of compliance at a 90,000-customer bank in Libreville, handles about 1,800 screening alerts a month with 6 analysts, in spreadsheets. Each alert takes 12 minutes on average, or 360 hours a month.
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- With a well-tuned fuzzy matching engine and automatic pre-qualification, the target is 60 % fewer false positives and 7 minutes per alert.
- New volume: 720 alerts a month, or 84 hours. Saving: 276 hours a month, about 1.7 full-time equivalents.
- At FCFA 900,000 fully loaded monthly cost per analyst, savings reach about FCFA 1,530,000 a month, or FCFA 18.4 M a year.
On the complex range of FCFA 7 to 15 M+, payback falls between 5 and 10 months, before counting the lower risk of sanctions at inspection.
FAQ
Will COBAC accept custom software?
COBAC assesses how effective the framework is, not the tool's brand. It checks that 100 % of transactions are screened, that alerts are handled within documented timeframes and that every decision is justified and kept for 10 years.
How do we keep sanctions lists up to date?
UN, EU and OFAC lists are published free of charge and can be downloaded automatically every day. PEP and adverse media databases are commercial, roughly FCFA 5 to 20 M a year depending on the provider.
How many false positives should we expect?
Banks of this size often see more than 90 % of screening alerts turn out to be false positives. Tuning by list type and whitelisting recurring beneficiaries can often halve the volume.
Can the system prepare reports for ANIF?
Yes, the suspicion file gathers the transactions, KYC documents and analysis, then generates the report in the expected format. Filing is still approved by the authorised reporting officer, with every step time-stamped.
What if we change core banking systems?
Connectors are isolated from the compliance engine. A core change takes roughly 4 to 8 weeks to adapt the feeds, priced in the quote, without rewriting the scenarios.
Let's scope your project. We work with your compliance team on scenarios, core banking connectors and a timeline that fits your next inspection. Detailed quote within 48 h. WhatsApp +221 77 596 93 33.
Mohamed Bah
Fondateur, Kolonell
Passionate about digital and entrepreneurship in Africa, Mohamed has been helping Sénégalese businesses with their digital transformation since 2020. Founder of Kolonell, he believes every SME deserves a professional and accessible online présence.
