Senegal crypto KYC AML compliance: the 2026 minimum
A Senegalese SME receiving or sending crypto-assets (USDC, USDT, BTC, ETH) is not a VASP, but remains subject to the general anti-money-laundering obligations of Senegalese law (Law 2018-03 on laundering and terrorism financing, transposing FATF directives). Off-ramps (Bitnob, Yellow Card) apply their own KYC, but the SME must also maintain a minimum compliance file.
In 2026, two main risks: (1) a transaction flagged by Bitnob as suspicious triggers a CENTIF investigation reaching back to the SME, (2) an international client flagged by OFAC or UN contaminates the SME by association.
Here is the KYC AML procedure checklist for crypto-active Senegal-based SMEs.
H2: Senegalese legal framework 2026
Law 2018-03. Defines obligations of "obligated persons": banks, fintechs, accountants, lawyers. An SME is not obligated under the main title, but must cooperate if questioned.
FATF Recommendations (R.15 + R.16). R.15: all VASPs must be regulated. R.16: Travel Rule — any crypto transaction > USD 1,000 between VASPs must transmit sender + beneficiary identity. Bitnob, Yellow Card apply this rule.
CENTIF Senegal stance 2025-2026. The Senegal Financial Information Processing Cell published in 2025 a note specifying: crypto flows > USD 5,000 involving a Senegalese SME may be subject to clarification requests via the ramp or directly.
H2: Operational thresholds 2026
| Transaction amount | Minimum SME procedure |
|---|---|
| < USD 1,000 | Keep hash + counterparty address + linked invoice |
| USD 1,000-5,000 | + Counterparty identity (legal name, country, light KYC) |
| USD 5,000-15,000 | + Documented source of funds + OFAC/UN screening |
| USD 15,000-50,000 | + Internal validation 2 persons + reinforced due diligence |
| > USD 50,000 | + Ramp notification (Bitnob alerts CENTIF automatically) |
H2: Counterparty identity verification
Individual. ID document (passport or national ID), proof of residence < 3 months, selfie with ID, source of funds declaration. Tools: Sumsub, Veriff, Onfido (EUR 50-200/year for low-volume SMEs).
Company. Statutes, commercial registry, KYB of beneficial owners > 25% (UBO), proof of activity (recent invoices, website). Tools: Middesk, Sumsub Business, KYB Veriff.
Diaspora special case. Senegalese diaspora in France/USA/Italy: resident card + proof of residence + proof of income source (payslips, business accounts). More flexible KYC if transaction < USD 15K.
H2: Sanctions screening
OFAC SDN List. US sanctions — any person or company on this list: transaction forbidden. Tools: Chainalysis Reactor, TRM Labs, free OFAC Search API.
UN Consolidated List. UN sanctions — applicable in Senegal (UN member). Monthly update.
EU. EU sanctions (useful if you invoice European clients) — applicable for Europe flows.
SME procedure. Before each transaction > USD 5K: verify counterparty name + company on OFAC + UN. Document the verification (dated screenshot). Cost: EUR 0 (free APIs) to EUR 500/month (Chainalysis for high-volume SME).
H2: FATF Travel Rule — concrete SME 2026
When an SME sends or receives > USD 1,000 via a ramp (Bitnob, Yellow Card), the ramp automatically collects: sender name, sender address, sender account ID, beneficiary name, beneficiary address. This data is transmitted to the VASP counterparty.
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SME implication. If you transfer USDC 5K from Coinbase to Bitnob for FCFA conversion, Coinbase transmits your identity to Bitnob. The SME must therefore accept this transmission (accepted by default in exchange ToS).
H2: CENTIF reporting
When to report. The SME itself does not report directly to CENTIF (unless "obligated person" — rare). But must cooperate if CENTIF requests clarifications via its bank or the ramp.
Preparation. Maintain a crypto transaction registry (date, USD/FCFA amount, counterparty, hash, commercial purpose). Keep 10 years. Free format (Excel, Notion, ERP).
Response delay. If CENTIF requests info via the bank: 5 business days to respond. Otherwise suspicion presumption.
H2: Internal SME procedure checklist
- Designate an internal Compliance Officer (can be CFO, senior accountant, or external lawyer on retainer).
- Draft a 4-page AML procedure: thresholds, verifications, escalations, retention.
- Train 2-3 people (CEO, CFO, accountant) — 1 half-day suffices.
- Tool up: Sumsub light + OFAC API + transaction registry spreadsheet.
- Quarterly audit: review 10 random transactions, verify file completeness.
- Keep 10 years all supporting documents (Law 2018-03).
FAQ
Am I subject to Law 2018-03 as an export SME?
Not under main title (you are not a bank or VASP). But you must cooperate in case of CENTIF request, and prudence dictates applying a proportionate light AML.
How much does a minimum 2026 KYC AML setup cost?
Low-volume SME (10-50 transactions/year): EUR 300-800/year (Sumsub light + free OFAC API + internal time). Medium-volume SME (100-500 transactions/year): EUR 1,500-4,500/year. Fintech SME (>1,000 transactions/year): EUR 8,000-25,000/year (Sumsub Business + Chainalysis).
What to do if a client is OFAC-flagged after transaction?
Stop immediately any new transaction. Notify the ramp (Bitnob, Yellow Card) so it alerts CENTIF. Keep all supporting documents. Consult compliance lawyer. Risk: penalties if repeat, but documented good faith protects.
Does Travel Rule apply to non-custodial wallets?
Officially no (a MetaMask wallet is not a VASP). But as soon as you send to or receive from a VASP (Bitnob, Coinbase), the Travel Rule activates on the VASP side. Consequence: your identity is transmitted to the other VASP.
How long to keep supporting documents?
10 years (Senegalese Law 2018-03 aligned with FATF). Keep: blockchain hash, counterparty ID, linked invoices, OFAC screening screenshot, internal validation. Secure storage (Notion, encrypted business Drive, or notarial archiving).
Let's talk about your case
If you want to draft your SME KYC AML procedure or audit your existing compliance, we can set up. 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.
