Ivory Coast - Threat Assessment - 2020 Page 1 of 31 Sanctions & Terrorism: No Comprehensive � Sanctions against the Country, though some former senior leaders are still designated. For Section 1 - Executive Summary Proliferation Tier 3 PPI (Proliferation) Index, reflects lowest threat level but a low score of NRA: The Ivory Coast National Risk 360/1,300 for Controls. Terrorism ratings from Assessment has not yet been published, GTI give Ivory Coast a “Low” impact (Score though the assessment is under way and 2.598/10) 72nd highest out /138. commenced in January, 2019. It is expected to be published in late 2020. Indices: Freedom House 2019 Freedom in the World Report - score 51/100, “partly free”, Grey Lists: The Ivory Coast is not listed as one 54.5/100 in the Mo Ibrahim Index of African by the US as a Country of Primary Concern in Governance, & 6.62/10 ranked 18th worse respect of ML & FC, is not listed by FATF, or the from 129 countries in the Basel AML Index. EU on their Grey lists. Response & Resilience: The Ivory Coast, Corruption: TI CPI - 2019 - ranked the Ivory Coast scores 4.54 for resilience, (response), ranked 106/180, with a score of 35/100 in 2020, (no 18/54 Africa and 6/15 for West Africa in the change on 2018) a score below 50 is indicative of a OC Index. It was last evaluated in 2012, against country struggling with corruption issues. FATF standards, with results reported in 2013 Organised Crime: “High Criminality and Low with no ratings of “Compliant,” with the 40 Resilience” in the OC Index, with a criminality Recommendations, 6 for “Largely score of 6.23, ranked 8/54 Africa & 2/15 W Compliant” (LC),18 for “Partially Africa. The main markets, with highest Compliant” (PC), 24 for “Not Compliant” (NC), criminality scores are Illegal Logging & Mining and 1 Recommendation considered “Not (7.5/10), Human & Arms Trafficking (7/10), Applicable” (NA). The next evaluation, is Wildlife Crime (6.5/10), Drug Trafficking expected to start in February 2021. (Cannabis & Synthetics (6/10) & Human Smuggling 5/10. On Groups, State enabled Overall Ratings: Ivory Coast is rated overall actors (8/10) received the highest score, “Mod - High” Risk, 4th highest risk out of 13 followed by Criminal networks, and Foreign West African Countries and 13th highest risk actors (7.5/10), and Mafia style groups (3/10). out of 40 in FCN’s SSA Threat Assessment with a score of 45/100, and with an “Improving” Slavery: US Trafficking in Persons: Tier 2 trend. Country; Global Slavery Index: 56/167 Countries, 31/51 African Countries, with FCN Rating “Mod - High” Risk 45/100 137,000 modern day slaves, incidence of Trend “Improving” 5.9/1000 people and a “B” response.

Ivory Coast - Threat Assessment - 2020 Page 2 of 31 Section 2 - Country Dashboard

Ivory Coast ↗ Improving Capital/Population: /Abidjan / 27.5 million (2020) President: President Alassane Dramane Quattara (since 2010) GDP: US$43 billion (2017) (2.7% of SSA GDP) Economic Sector Breakdown: Agriculture (20%), Industry (27%), Services (53% Exports: US$11.7 billion (2017 est.) Cocoa , coffee, timber, petroleum, cotton, bananas, pineapple, palm oil, fish to Netherlands 11.8%, US 7.9%, France 6.4%, Belgium 6.4%, Germany 5.8%, Burkina Faso 4.5%, India 4.4%, Mali 4.2% (2017) Imports: US$9.4 billion (2017 est.) fuel, capital equipment, foodstuffs from Nigeria 15%, France 13.4%, China 11.3%, US 4.3% (2017).

Score: 45/100 “Mod-High” FCN Risk Rating (Average Country Score is 32 - SSA ) Proceeds / Laundering Rank: 16/40 SSA - 6/13 Region WA range 8% - 11% GDP / 40 - 50% of Proceeds

Organised Crime Costs of Corruption range up to approx 34 - 36% of Proceeds range up to approx 10 - 15% of Proceeds (State Enabled 8/10, Criminal Networks 7.5/10, Foreign Actos 7.5/10, Mafia Style 3/10)

Ivory Coast Higher (Inherent) Risk Factors Total Criminal Proceeds in Sub Saharan Africa in US$ Billions - FCN Customer Sector Country 2020 (not including fraud and Risks Risks Risks corruption and tax evasion)

Customers with elevated Banks (in particular Retail Neighbouring Countries exposures to: and Correspondent in particular & Banks) Guinea (Smuggling) Mali (Terrorism AQIM / AD) Mining Fishing Criminal activities such as: Other FI’s such as Bureau 10 2.5 Illegal Logging & Mining, de-Change, MSB’s MMO’s Wildlife Goods Piracy Lebanon (Terrorism 2 Human & Arms Trafficking, 9 DNFBP’s including Finance - via support for Wildlife Crime & Drug precious metals and Hezbollah) Trafficking, & Smuggling stones dealers Logging along with Corruption (e.g Major Export / Import 12.5 PEP’s) which also helps Informal Sectors Partner Countries (Trade Modern Slavery Mispricing and IFF’s - 8.3 facilitate these crimes & particularly mining and Tax Evasion as a high risk extraction sectors) Drugs concern also. 3 Theft Latin America (drugs) & 15 SE Asia (wildlife) to Higher Risk Sectors and/or Geography Risks

FCN SSA Country Risk Rating by FCN - “Mod” Threats by FCN -

GTI GSI INCSR TI CPI US TIP WEF OC GFI IFF’s Overall US Terror IUUF Index OC Index US END Wildlife

FCN SSA Country Risk Rating by FCN - “Low - Mod” Response -

GSI PPI Gov Free Basel OCI NRA FATF 40 FATF 11 Overall Seizures US$ FATF/EU Lists

Ivory Coast - Threat Assessment - 2020 Page 3 of 31 Section 3 - Country Information

People & Geography: The Ivory Coast is bauxite, copper, gold, nickel, tantalum, silica home to almost 27.5 million people (estimated sand, clay, coffee & palm oil. 2020), with most of its inhabitants living along the coastal region and in the economic capital, Cocoa: The Ivory Coast is the worlds leading Abidjan, with the interior sparsely populated. supplier of cocoa, with cocoa accounting for The Ivory Coast landmass is mostly used for 40% of total exports and 10% of GDP or Agriculture and forestry, though whilst fresh US$4.3 billion. There are estimated to be cover a decade ago was at 30% most of the 600,000 farmers (paid approx 54 cents a day) - Country’s forests, have been cleared through and about 6 million people working in the deforestation. Water pollution from sewage, cocoa industry, with child labour extensive - and from industrial, mining, and agricultural with around 6.6% of final retail price of effluents is also a concern. The Ivory Coast has chocolate going to growers. 515 km of coastline, and an exclusive economic fishing zone of 200 nautical miles Gold & Diamonds: Gold production reached into the Atlantic Ocean. 23,5 tons in 2015, valued at US$857 million. Illegal Mining is widespread, particularly in the Recent History & Leadership: The Ivory Coast regions of Bounkani and Gontougo, with many achieved its independence from France in farmers turning from cocoa to illegal mining. 1960, but retains close ties, with French the Diamond production generated approx US$5 official language. In December 1999, a military million in exports in 2016. coup overthrew the government, with in time coming into power. A failed Fishing: Represents 0.8% GDP or US$388 coup attempt in 2002 developed into a civil million, with 3 local tuna processing plants war, which by 2003, resulted in the country exporting canned tuna. Other popular catches being divided between the north and the include sardines and shrimp. south, and peacekeeping forces in between. In 2007, an agreement to reunite the country was Forestry: Ivory Coast produced in 2015 about made and after delays, won 2.5 million m3 of logs, which was primarily new presidential elections and with the help of used in the domestic industry. Exports were UN and French forces came to power. Outtara valued at US$218.4 million in 2015 (0.5% won a second term in 2015. The UN GDP). peacekeeping mission departed in June 2017. Gbagbo was in The Hague on trial for crimes Environment: According to the Environmental against humanity, but was acquitted in 2019. Protection Index 20181. The Ivory Coast is Next Presidential elections are scheduled for scored 43.41/100 & ranked149/180. November 2020. Outtara announced he will not stand. Finance: The Ivory Coast financial profile2 includes the following (people aged over 15); Economy & Trade:The Country is known for 15% have Bank account’s, 1.3% have a credit cocoa production, but has other natural card, 34% have a mobile money account, 7.1% resources including petroleum, natural gas, make online payments, Internet penetration is diamonds, manganese, iron ore, cobalt, at 47% via 12 million internet users 34 million mobile connections or 131%.

Ivory Coast - Threat Assessment - 2020 Page 4 of 31 Section 4 - Country Ratings & Country Threats Heat Map

Source Ivory Coast � Source Ivory Coast � Source Ivory Coast �

World Economic Forum 51.3 / 100 Transparency International (TI) 35 / 100 Proliferation Index - PPI Tier 3 Organised Crime Index* Corruption Perceptions Index* Threat Lowest Threat Level

OC Index “High” Criminality TI & Afrobarometer 34% Proliferation Index - PPI 360 / 1300 Criminality* 6.23 Citizens Views and Experiences of Corruption Controls* Low Controls score Report

OC Index 6.5/10 TRACE No Rating Global Terrorism Index “Low” Impact Criminal Actors Bribery Risk Matrix GTI - Impact* 2.598

OC Index 8/10 Global Slavery Index 5.9/1,000 US Dept of State No State Embedded Actors GSI Incidence* Incidence Country Reports on Terrorism*

OC Index 7.5/10 Global Slavery Index 137,000 Global Cybersecurity Index 3.276/10 Criminal Networks No of estimated Modern Day Slaves Total numbers 2018 (63/175)

OC Index 7.5/10 Global Slavery Index “B” Rating Mo Ibrahim Governance Index 54.5/100 Foreign Actors Country Response Rating* (49.9 - All Africa)* “Increasing Improvement”

OC Index 3/10 US Dept of Labor 31.5% Freedom House 51/100 Mafia Style Gangs Child Labour of 4-15 year olds are working (1.67 Freedom Index* “partly free” million)

OC Index Cannabis & Synthetic’s 6/10 US Dept of State Tier 2 Rated Heritage Foundation 59.7/100 Drugs Trafficking Heroin 4/10 - Cocaine 3/10 Trafficking in Persons* Economic Freedom Index “Mostly unfree”

OC Index 7/10 IOM Migration 933,000 E/411,000 I Basel AML Index* 6.62/10 Arms Trafficking E - Emigration / I - Immigration

OC Index 5/10 Illegal Unreported and Unregulated 2.24/5 FIU Egmont 2010 People Smuggling (IUU) - IUU Fishing Index Gulf of Guinea is a global hotspot for Member illegal fishing

OC Index 7/10 EU Listing of Countries for Illegal No Interpol Yes Human Trafficking Fishing Member

OC Index 7.5/10 US DoS - Wildlife Trafficking No Asset Confiscations Estimated below 1% Illegal Timber Focus / Countries of Concern* over 1% of Proceeds*

OC Index 6.5/10 Environment Performance Index 43.41/100 Country National Risk Assessment* Not Yet Illegal Wildlife 149/180 Expected in 2020

OC Index 7.5/10 EUIPO & OECD Counterfeit Goods 0.170 Financial Information Sharing No Illegal Mining Including Gold & Diamonds Propensity of Exports (2017) Partnership

OC Index 4.54/10 Tax Justice Network Not Included US Dept of State Not Resilience* Financial Secrecy Index INCSR Vol I & Vol II* Listed

OC Index 4/10 EU List of None Co operative Not Included European Union List* AML Jurisdictions for Tax purposes No

OC Index 4/10 Not Yet Reviewed FATF Standards MER to start in 2020 OECD - Global Forum Law Enforcement on Transparency & Exchange Info for Tax Purposes 40 Recommendations*

OC Index 6/10 Global Financial Integrity US$1.36 billion FATF Standards MER to start in 2020 International Co- operation Illicit Financial Flows* (2017) - 16.03% of Trade 11 IO’s on Effectiveness*

OC Index 5/10 Embassy’s from N Korea, Syria, Iran Iran FATF Standards MER to start in 2020 Economic Regulatory Environment or Cuba Core 10 Recommendations

Illegal Drug Dependency / Disorders 464,000 Embargoes - Country Sanctions FATF Standards MER to start in 2020 Number/Share 0.5% (Comprehensive - UN, US, EU, UK) No Core 4 IO’s on Effectiveness

Numbeo Crime Survey 2020 No Rating OFAC Listed Parties 3 FATF with Local Addresses Counter - Measures No Strategic Deficiencies List*

FCN Final Ratings - Ivory Coast �

Financial Crime News 50/100 Financial Crime News 45/100 “Mod - High” Risk Threat Rating Financial Crime Rating “Moderate” Threat 13/40 SSA - 4/14 WA

Financial Crime News 39/100 Trend Improving Response Rating “Low - Mod” Response (TI CPI, Mo Ibrahim, FATF, Basel Index & GTI - 3-5 years)

For more details on the scoring model for FCN Ratings contact the Editor FCN directly for access to the Methodology

Ivory Coast - Threat Assessment - 2020 Page 5 of 31 Section 4 Continued - Country Threats Heat Map

There are many threats that effect the Ivory Coast, which are in most part targeted towards its resources, it’s trading status and its port as well as its natural resources, the people, wildlife, metals, minerals, gems, forests, crops and fish. The effect of endemic corruption increases the threats and reduces the ability to effectively respond. For more details in summary form see the figure below.

Ivory Coast - Threat Assessment - 2020 Page 6 of 31 Section 5 - Key Threats

In this Section 5, the most important criminal jurisdiction of concern (but not of primary markets, are assessed and summarised based concern) in the INCSR4 in 2016. on available sources. It stated that; “despite a more stable political 5.1 NRA: The Ivory Coast National Risk environment and increased prosecutions in Assessment (NRA) has not yet been published, 2015, Ivorians continue to be involved in though the assessment is under way and regional criminal activities, such as the commenced in January, 2019. It was expected smuggling of consumer goods and agricultural that this NRA will be completed and published products, and in the subsequent laundering of in late 2020. the proceeds. Smuggling over Cote d’Ivoire’s porous borders, motivated in part by a desire Not yet published - was expected in to avoid duties or taxes or to sell goods at a 2020 higher profit, generates illicit funds that are National Risk Assessment primarily laundered via informal value transfer The NRA is expected to identify Illegal Logging systems, such as money service businesses or & Mining, Human & Arms Trafficking, Wildlife exchange houses, and via mobile telephone Crime, Drug Trafficking & Smuggling along payments or transfers (M- Payments). Many with Corruption which also helps facilitate Ivorians use informal cash couriers, money and these crimes and Tax Evasion as a high risk value transfer services (MVTS), hawaladars, and concern also. goods transportation companies to transfer funds domestically and within the region. It is expected that Banks and other financial There is no regulation of domestic informal institutions as well as DNFBP’s have been MVTS. There are concerns about the increase in identified to be the main sectors that are cyber theft through online commercial vulnerable to laundering the proceeds of transactions. In addition, Ivorian authorities crime. believe criminal enterprises use the formal Ivory Coast is not listed banking system, as well as the used car, real US INCSR 2019 estate, and counterfeit pharmaceutical drug industries to launder funds. The use of Ivorian 5.2 US INCSR: Whilst the Ivory Coast is not territory as a transshipment point for drugs listed as one of 80 Countries categorised by from South America to Europe has decreased the US State Department as a Country of with the creation of new routes by drug Primary Concern in respect of Money traffickers after the Arab spring and tightened Laundering and Financial Crimes in their airport security. International Narcotics Control Strategy Report (INCSR)3 in 2019, the Ivory Coast was a named

Ivory Coast - Threat Assessment - 2020 Page 7 of 31 5.3 Corruption: Corruption is not only a Ouattara's internationally recognised victory in significant generator of illicit funds, but it is the November 2010 Presidential election. In also an enabler of other serious crimes and 2015, Mr Ouattara won a second five-year term protects those involved from investigation, with nearly 84% of the vote, in an election prosecution and or conviction. Estimates of described as “credible” by US observers. losses due to corruption of up to 30% of State The 2018 TRACE Bribery Risk Matrix6 places Revenues have been reported elsewhere in the Ivory Coast in the “High” risk category, SSA, which if applied to the Ivory Coast would ranking it 138 out of 200 surveyed countries, generate US$2.5 billion. with a risk score of 62/100. According to Transparency International’s “high risk” for corruption Corruption Perception Index 2019 (CPI - 2019), TRACE - 2018 the Ivory Coast was ranked 106 highest out of 180, with a score of 35/100 in 2019, (no TI & Afrobarometer Findings 2019 (% Survey) - � change on 2018).

58.0 49.0 TI - CPI Scores (out of 100) - � 40.0 34.0

”Increasing” ”Doing Badly” ”Paid Bribe” ”Most Corrupt - Police”

36.0 35.0 According to TI & Afrobarometer Citizens 27.0 22.0 Views and Experiences of Corruption Report

7 2010 2013 2016 2019 published in 2019 , (covering the period 2016-2018): Whilst a score below 50 is indicative of a country struggling with corruption issues, Ivory • 40% of Ivorians surveyed thought corruption Coast has seen dramatic improvements in its had increased in the previous 12 months, score over the last decade, for example the versus an African average of 55%. country scored 22 in 2010, 27 in 2013, 32 in • 58% thought the Ivory Coast was doing 2015, and a high of 36 in 20165. This has seen badly in fighting corruption, versus an the Ivory Coast ranked 154th in 2011 and African average of 59%. improving to 106th out of 180 in 2019. • 1 in 3 (34%) Ivorians surveyed reported These improvements can be attributed to the paying a bribe to use public services in the improving conditions, Ivorians have previous 12 months versus a 1 in 4 (25%) experienced since the coming to power of African average. President Alassane Ouattara, who replaced, Laurent Gbagbo, who was forcibly removed • As far as public institutions were concerned, from office after refusing to accept Mr perceptions of corruption by those surveyed

Ivory Coast - Threat Assessment - 2020 Page 8 of 31 rated the Police as the most corrupt (49%), • Drug Trafficking (Cannabis & Synthetics followed by Business Executives (44%) (6/10), Heroin (4/10), Cocaine 3/10)) & Government Officials (33%), Local • Human Smuggling 5/10. Government Officials (32%), MP’s (30%), Judiciary (31%), President (27%), NGO’s On Groups, the Ivory Coast has a wide range (18%), Religious Leaders (13%) & Traditional of influential criminal actors driving the Leaders (15%). country's illicit economies. State-embedded actors receive the highest score of the four 1 in 3 (34%) Ivorians paid a bribe / actor types, reflecting deep-rooted corruption Police -the most corrupt (49%), by the authorities at 8/10, followed by Criminal followed by Business Executives (44%) TI & Afrobarometer - 2019 networks, and Foreign actors - 7.5/10, & Mafia style groups - 3/10 5.4. Organised Crime: According to

Organised Crime Index (OCI),8 in 2019, the OC Index - Criminal Actor Types - Importance - � Ivory Coast is rated as “High Criminality / Low Resilience”.

7.5 8.0 7.5 The Ivory Coast had a High Criminality score of 6.23, ranked 8th highest of 54 in Africa and 3.0

2nd highest of 15 In West Africa, and a score of Criminal Networks State Enabled Foreign Actors Mafia Style 4.54 for resilience, (response), ranked 18th According to the OCI9, “Criminal actors in Côte lowest of 54 in Africa and 6th lowest in 15 for d'Ivoire operate primarily as part of criminal West Africa. networks. Many local criminal networks are OC Index Criminal Markets - Importance - � involved in illegal gold mining, drug trafficking, smuggling, contraband sales, trafficking of endangered animal species and money

7.0 7.5 7.5 7.0 laundering. Most are generally low-level 6.0 6.5 6.0 5.0 couriers serving criminal and trafficking networks based in neighbouring and countries Synthetics Wildlife HT Mining Logging Arms Cannabis People Smugg further afield. Most of the illicit economies The main criminal markets, according to the prevalent in Côte d’Ivoire are facilitated in OCI, with the highest criminality scores are; some way by foreign actors, with whom

• Illegal Logging & Mining (7.5/10), domestic criminal networks have extensive connections. Networks in Latin America play a • Human & Arms Trafficking (7/10), major role in drug trafficking through the country, while illegal wildlife crimes are often • Wildlife Crime (6.5/10), committed with the help of criminal actors from

Ivory Coast - Threat Assessment - 2020 Page 9 of 31 Asia, who act as an interface between the livelihood for many, including former country of origin and the end markets. Mafia- combatants and government officials. Although style groups are also present in Côte d’Ivoire, illicit gold mining occurs in large parts of the some of which use the same names as their country, violence associated with it appears to Italian counterparts, controlling territory. These be minimal.” armed groups engage predominantly in 5.5.3 Environmental “Green” Crimes: Illegal trafficking of children.” Fishing: The Ivory Coast has 797 Km’s of 5.5.1 Environmental “Green” Crimes: Illegal coastline, adjacent to what were once Timber: According to the OCI10, “the country abundant West African fishing grounds. These has one of the highest deforestation rates in fishing grounds still contain large stocks of Africa, and although most of the forest loss is a fish, which migrate up and down the West result of farming practices, there is substantial African coast and provide a vital source of deforestation caused by illegal logging protein for the population, as well as providing perpetrated by criminal networks. Furthermore, jobs. The Country’s overall scored 2.24 (African in recent years, timber has been used as an average 2.38/5 - with 5 being the maximum obfuscation method for illicit wildlife trafficking score and ranked 26th/38) in the IUU Fishing out of the country's maritime ports, such as Index 2019, with a low prevalence score (1/5) Abidjan.” It has been estimated that up to 40% but a higher vulnerability score (3.11/5) and of cocoa farming is from coca trees, that have response (2.43/5)13. replaced the natural habitat in protected areas11. The Ivory Coast is a source Country (Pangolin) and Transit Up to 40% of cocoa farming is from Country for Pangolin and Elephant coca trees, that have replaced the Ivory from West and Central Africa natural habitat in protected areas Institute for Security Studies 2018 destined for Asian Markets Institute for Security Studies 2018 5.5.2 Environmental “Green” Crimes: Illegal 5,5,4 Environmental “Green” Crimes: Illegal Mining: According to the OCI12, “Gold is one Wildlife: According to the OCI14, the Country of the main resources found in the northern is both, “a transit and origin country for the part of Côte d'Ivoire, and much of it is mined trafficking of ivory by criminal gangs, and plays illegally. The exploitation is conducted by a major role in the illegal ape and birds’ farmers. Leaders of a rebellion in the country markets; corruption is linked to these have seized control of mines, generating tens networking routes and activities.” These of millions of dollars a year. These actors activities are carried out by criminal networks engage in illegal taxation, smuggling and and supported by state embedded actors, with racketeering. Illegal mining provides a corruption playing a significant role.

Ivory Coast - Threat Assessment - 2020 Page 10 of 31 Ivory Coast - Threat Assessment - 2020 Page 11 of 31 According to the Institute for Security Studies15 following days. Trafigura, was fined over €200 pangolin scales and elephant ivory are the million and remediation and compensation most trafficked wildlife products in the country, payments. sourced from the Ivory Coast (in the case of According to United Nations Environmental Pangolin) and from other countries in the Project in a Report published in 201518, a region, such as West, East and Central Africa, number of waste concerns are identified destined for Asian markets. Since 2016, Côte including: d’Ivoire has recorded at least five major wildlife-trafficking events involving seizures • the increasing size of the city of Abidjan and arrests. A January 2018 seizure16 resulting in range of environmental issues revealed 578kg of ivory and over half a ton of including water pollution, inappropriate pangolin scales, leopard skins and other items, disposal of hazardous and municipal waste with the pangolin scales probably poached and severe land degradation and harvested in Côte d’Ivoire, while the • the state of the Ébrié Lagoon, which is elephant tusks came from Gabon, Nigeria, severely polluted and being further Mozambique and Uganda, all destined for degraded due to disposal of solid and liquid Vietnam. Four suspected of organising the waste, with evidence of heavy metal and shipments, were 1 from each of Ivory Coast, pesticide pollution in the fish Guinea, China and Vietnam.

• the state of the artisanal mining sector is As a result of deforestation, including due to flourishing but there are serious health and cocoa plantations replacing traditional forests safety issues in the sector. in protected areas17, primate populations have sharply declined. Air pollution in the Ivory Coast is the cause of 7.5% of all deaths19, (with a range of third 5.5.5 Environmental “Green” Crimes: Illegal countries with better air quality at 2%). Waste: In 2006, an infamous waste management incident occurred off the coast of the Ivory Coast. A mixture of over 500 tons of Air pollution causes 7.5% of all deaths / toxic waste was dumped at 18 sites around 4 million people do not have access to

Abidjan. The commodities trader Trafigura had safe drinking water. Various - 2017 tried to save charges in Europe, sent a vessel to several countries which rejected the Water pollution is also a significant challenge. hazardous substances, and finally disposed of Over 8 million people lack access to adequate the load for allegedly US$17,000 near Abidjan. sanitation facilities, which increases the risk of This event led to the deaths of 15 people, 69 water-related diseases. Over 4 million people people were hospitalised, and over 108,000 lack access to safe drinking water. These others sought medical treatment during the numbers increase in rural areas, where 46% of Ivory Coast - Threat Assessment - 2020 Page 12 of 31 the rural population lacks access to clean water labor in the agricultural and service industries, and 87% lacks access to sufficient sanitation20. especially cocoa production.”

Forced labour (including child labour) 5.6 Human Trafficking: According to the identified in the cocoa, coffee, Global Slavery Index21 released in 2018, the pineapple, cashew, rubber, animal Ivory Coast was ranked 56/167 Countries, breeding, mining, carpentry & 31/51 African Countries, with 137,000 modern construction industries day slaves, and an incidence of 5.9/1000. US TIP 2018 people but with a high level “B” response. The widespread use of children in cocoa 137,000 HT Victims production is well documented24, with a study, GS Index 2018 published in Fortune Magazine in 2016, GSI estimate in Africa 63% are modern slaves concluded that approximately 2.1 million through Forced Marriage (86,310) and 37% in children in West Africa "still do the dangerous forced labour (50,690) with 6% (8,220) in Forced and physically taxing work of harvesting Labour via Sexual Exploitation. Based on ILO cocoa". Whilst West Africa, collectively supplies 22 estimates , the profits from Sexual Exploitation are approx 70% of the world's cocoa, 35% of highest at US$11,000 a year, Forced Labour none world cocoa is supplied by the Ivory Coast. agriculture at US$3,000 and in Agriculture US$1,000. Based on these figures proceeds of Outside of cocoa, other agricultural sectors US$132 million a year may be generated (with have been identified as using forced labour, 100% assumed to be none Sexual Exploitation including child labour, on “coffee, pineapple, Forced Labour in Agriculture). cashew, and rubber plantations, and in animal breeding) and in mining, carpentry, The Ivory Coast is rated as a Tier 2 Country in construction, and begging in Côte d’Ivoire25. the US Trafficking in Persons Report23 2019.

The TIP 2018 stated; “human traffickers exploit Forced child begging, by young students from domestic and foreign victims in Cote d’Ivoire, Quranic schools has also been identified, in and traffickers exploit victims from Cote d’Ivoire northern and central parts of the Country, as abroad. The majority of identified victims are well as reports that, “drug traffickers use children; due to a stronger emphasis on children—some of whom may be forced—to sell combating internal child trafficking, the and traffic drugs in restaurants and prevalence of adult trafficking may be nightclubs26.” underreported. Some Ivorian women and girls are subjected to forced labor in domestic According to the the US department of Labour, service and restaurants and exploited in sex through its Bureau of International Labour trafficking. Ivorian boys are victims of forced Affairs 31.5% of children aged 5-14 working in the Ivory Coast and 21.5% of children aged

Ivory Coast - Threat Assessment - 2020 Page 13 of 31 Ivory Coast - Threat Assessment - 2020 Page 14 of 31 5-17 are “engaged in hazardous work.” with scale farmers, many of whom have little forced labour, child labour and forced child alternative sustainable livelihoods. labour most common in cocoa and coffee OC Index - Drug Trafficking - Importance - � production27.

5.7 Arms Trafficking: Due to the country’s 6.0 6.0 recent conflicts, it has experienced an increase 4.0 3.0 in the flow of arms, with arms trafficking rates high according to OCI28 at 7/10. The presence Cocaine Synthetics Cannabis Heroin of a substantial numbers of weapons, no 5.9 Fake Drugs: Fake medicine is a major longer required in the Ivory Coast, has led to problem in much of West Africa, with the Ivory the Ivory Coast being a source country Coast, particularly affected, in particular fake supplying those requiring arms, in other vaccines, antibiotics and counterfeit malaria conflict areas, across the region. medicine, which are sold widely in the streets,

The Ivory Coast’s representative to the UN in markets and bus stations, particularly in 2019 in a debate on small arms, said the Abidjan. Though the police carry out frequent “proliferation of small arms and light weapons operations targeting sellers of these is a cause of major concern because it is linked unregulated medicines, the authorities have to drug and mineral trafficking and to terrorism, found it very difficult to disband the criminal constituting an impediment to peace, security networks behind the trade. In May 2017, and development. More than 100 million Ivorian authorities incinerated close to 40 illegal small arms are currently circulating in tonnes of fake medicine seized in Adjame, a Africa, 10 million of them in the Sahel region, neighbourhood in Abidjan. According to the fuelling insecurity29.” WHO, at least 100,000 people die each year in Africa from fake medicine31. 5.8 Drug Trafficking: According to the OCI30, Drug Trafficking involves mostly Cannabis & 5.10 People Smuggling: The route from West Synthetics (6/10), with Heroin (4/10), and Africa to the North and then onwards into Cocaine (3/10) less important. Libya and then to Europe has been one of the most common routes taken by migrants, Cannabis has been grown for helped by people smugglers along the way. consumption and export in West Africa This route though is being affected as a major for decades deterioration in the security situation in the Various Sahel region is reported. The alternative route Cannabis has been grown for consumption appears to be changing towards Morocco and and export in West Africa, for decades with the Algeria and into Spain32. crop providing significant revenue to small-

Ivory Coast - Threat Assessment - 2020 Page 15 of 31 Ivory Coast - Threat Assessment - 2020 Page 16 of 31 5.11 Fraud and Cybercrime: According to the average African figure of 16.2%, ranking it 18th Ivorian government, it received more out of 40 SSA Countries (with the 1st being the complaints about cyber criminality in the first lowest Tax to GDP Country), and rated as a half of 2013 than any other country on the “Medium” Tax Collection Country in Africa, by African continent, making it then Africa's the African Union. unlikely capital of "brouteurs" - Ivorian slang 5.13 Overall Threat Level: According to FCN, for cyber criminals, with phishing, hacking, the overall FC Threat Level is rated as phreaking, and 419 scams all on the rise. “Moderate” Threat (50/100), ranked equal 18th The average age of a cyber criminal in Ivory highest out of 40 countries assessed. Coast is thought to be between 16 and 17, each making around US$13,000 a month, and estimated as generating more than US$15 million, mostly from cyber enabled fraud carried out against people overseas over the last two years.

According to Ivory Coast police, "It's less risky to commit a crime with a computer than to do the classical crime that we were seeing in Abidjan in the '90s and 2000s, with lots of bank robberies by very young people. We don't see that any more,” and all the young people have dropped the guns and the cars to commit a cyber crime33.”

5.12. Tax Evasion: Tax evasion is expected to be highlighted in the NRA as one of the major concerns from an Ivory Coast perspective.

Illicit Financial Flows of (average per year) US$2.33 billion between 2004-2013 African Union 2019

Just on the basis of lost taxes on illicit financial flows, the Ivory Coast is estimated to have lost significant sums. The Ivory Coast has a Tax to GDP ratio of 15.1%34, which is below the

Ivory Coast - Threat Assessment - 2020 Page 17 of 31 Section 6 - Sanctions & Terrorism

In this Section 6, the focus in on Sanctions and country, from violent Islamist groups like AQIM Terrorism threats. and Ansar al-Dine,”

6.1 Sanctions: The Ivory Coast is no longer Despite this, the Ivory Coast suffered its first subject to significant international sanctions, terrorist attack on March 13, 2016 on the after the UN lifted restrictions in 2014 beaches of Grand Bassam, for which Al Qaeda (diamonds) and in 2016 (arms, asset seizures, in the Islamic Maghreb (AQIM), subsequently travel bans - though some former officials claimed responsibility. The attack left 19 remain designated on Sanctions lists). In 2014, people dead, including 16 civilians and 3 the UN lifted the ban on exporting rough Ivorian soldiers. diamonds from the Ivory Coast, after the According to the Counter Extremism Project40, Country was found to be Kimberley Process the “vast majority of suspects tied to the March compliant. 2016 attacks at Grand-Bassam are believed to The Ivory Coast is listed as a Tier 3 Country, come from outside the country. Nonetheless, according to the Proliferation Peril Index, though homegrown radicalisation to al-Qaeda reflecting a low potential proliferator threat, is not believed to pose a major problem, though also with a low controls score of support for foreign terrorist organisation 360/1,30035. There are no Cuban, Syrian, or Hezbollah is believed to be high. Of Côte North Korean Embassy’s in the Ivory Coast. d’Ivoire’s large Lebanese diaspora population, There is an Iranian embassy, based in Abidjan. 2015 findings from the Institute for Security Studies in Africa show that the majority Searching US OFAC’s36 database for Ivory consider Hezbollah a nationalist movement as Coast listings revealed 3 entries all relating to opposed to a terrorist organisation. Though the financing of Hezbollah. precise figures are not known, several Ivorians 6.2 Terrorism: Whilst the Ivory Coast is not are found to have joined foreign conflicts in included in US Country Reports on Terrorism Lebanon and Syria.” 201837 the US INCSR38 in 2016 included that According to the Global Terrorism Index (GTI), “Hezbollah is present in Cote d’Ivoire and the Ivory Coast is rated 72nd highest out /138 conducts fundraising activities, mostly among with a terrorism “impact” score of 2.5/10, down the large Lebanese expatriate community in from 4/10 in 2012 and 3.7 in 2016, the country.” representing a “low” impact of terrorism in the According to the Counter Extremism Project39, Ivory Coast. “the terrorist threat posed to Côte d’Ivoire is believed to come primarily from outside the

Ivory Coast - Threat Assessment - 2020 Page 18 of 31 Ivory Coast - Threat Assessment - 2020 Page 19 of 31 Section 7 - Money Laundering

In this Section 7, the focus is on the Ivory Europe. The amounts laundered in the Ivory Coast’s vulnerability to money laundering. Coast will include domestic proceeds and some proceeds generated in neighbouring 7.1 Higher Risk Areas: Higher risk areas have countries or overseas though these will be been identified through sources, including limited. Domestic Proceeds may also be those set out in this Country Threat laundered overseas, from corruption. Assessment. In many cases a single risk factor may not be evidence of actual higher risks, and 7.2 Cash Based Money Laundering: The higher risks may be more likely to arise where Ivory Coast remains a cash based economy, a number of risk factors are identified. though this is changing. Much of the day to day, person to person transactional activity Ivory Coast Higher (Inherent) Risk Factors occurs via exchange of cash for goods or Customer Sector Country services, with many areas of the country still Risks Risks Risks unbanked. It is therefore not unusual for Customers with elevated Banks (in particular Retail Neighbouring Countries exposures to: and Correspondent in particular Ghana & relatively large cash transactions to be Banks) Guinea (Smuggling) Mali (Terrorism AQIM / AD) Criminal activities such as: Other FI’s such as Bureau undertaken, including when purchasing high Illegal Logging & Mining, de-Change, MSB’s MMO’s Human & Arms Trafficking, Lebanon (Terrorism value assets, such as real estate, vehicles, gold DNFBP’s including Finance - via support for Wildlife Crime & Drug precious metals and Hezbollah) Trafficking, & Smuggling stones dealers and gems. along with Corruption (e.g Major Export / Import PEP’s) which also helps Informal Sectors Partner Countries (Trade Mispricing and IFF’s - facilitate these crimes & 7.3 Trade Based Money Laundering: Whilst particularly mining and Tax Evasion as a high risk extraction sectors) cash based money laundering is therefore the concern also. Latin America (drugs) & SE Asia (wildlife) principle and likely most popular method, for to Higher Risk Sectors and/or Geography Risks laundering funds, trade based money laundering is another. As the largest and Once the NRA is published, it is expected that busiest deep water port in West Africa, is at the banking sector, other FI’s and DNFBs will Abidjan, and with exports of almost US$12 be identified as the main sectors through billion and imports of over US$9 billion, which the proceeds of crime are channelled, to (representing almost half of the Ivory Coast’s the extent these formal sectors are used. GDP) the Ivory Coast is particularly vulnerable Criminal Proceeds are generated in the Ivory to money laundering via trade. Coast for example through sexual exploitation of forced labour, but also in neighbouring 7.4 Other Money Laundering: Securities, Countries, for example through smuggling Transaction and Virtual Currency laundering goods, and overseas, for example through are not considered significant. sales of illegal wildlife products, or cocaine in destination markets such as Asia and Western

Ivory Coast - Threat Assessment - 2020 Page 20 of 31 Main Criminal Markets % of Estimated Proceeds (not including Corruption) for Sub Saharan Africa overall - FCN

Logging 24% Goods 13%

Sex Exploitation Fishing 8% 11%

Wildlife 3% Drugs 4%

Mining Theft 14% Forced Labour 20% 3%

Ivory Coast - Threat Assessment - 2020 Page 21 of 31 Section 8 - Illicit Funds including Estimated Criminal Proceeds

In this Section 8, the focus is on the Ivory Whilst not all IFF’s are made up of criminal Coast’s vulnerability to Illicit Financial Flows activity, a significant proportion will be. and illegal Proceeds and to the laundering of According to the sources and analysis carried criminal and other illicit funds. out in this Threat Assessment, estimates for It is estimated that the Ivory Coast suffered criminal proceeds, laundered funds and funds from Illicit Financial Flows (IFF’s), with on generated by corruption and organised crime, average US$2.33 billion a year, from amongst others, are estimated in the following 2004-2013 according to the African Union41, ranges: and US$1.34 billion from • Total estimates for 2008-2017, according to Total Criminal Proceeds in Sub Saharan Africa in US$ Billions - FCN criminal proceeds 42 Global Financial Integrity 2020 (not including fraud and combined of 8 to 11%44 of (GFI), with US$1.36 billion corruption and tax evasion) GDP and with 10 - 15%45 estimated to have left the of this estimated as costs Country in 2017 through trade Mining Fishing 10 2.5 of corruption. misinvoicing representing a Wildlife 2 Goods Piracy 9 significant loss in taxes to the • Total estimates for Ivory Coast. Logging 12.5 monies available for Modern Slavery 8.3 laundering through the According to GFI, the most Drugs formal sector is 40 - 50%46 3 common method for Theft 15 of criminal proceeds and transferring illicit financial 34 - 36%47 involving funds, is through trade mis organised crime, with most pricing. GFI believe this significant criminal actors being foreign method or series of techniques may represent actors, closely followed criminal networks up to 80%43 of illicit financial flows, and can and then by state enabled and mafia style involve abusive and or aggressive transfer groups. pricing, trade mis pricing and mis-invoicing, for example intentionally overpaying for imports • The largest criminal markets in the Ivory of goods or services (or underpaying for Coast will include Corruption, Arms exports or services) is a straightforward way of Trafficking, Illegal Logging and Mining and illegally transferring monies out of a country. Wildlife, Smuggling, Human and Drug Trafficking, Tax Evasion, and those crimes The risks increase in trade with so called identified as the largest markets across Sub advanced economies. Saharan Africa (see Pie Chart above).

Ivory Coast - Threat Assessment - 2020 Page 22 of 31 Section 9 - Resilience & Response

In this Section 9, the focus is on the Ivory number of component parts which make up Coast’s level of resilience and response. the overall “Resilience” rating are:

9.1 FATF: The Ivory Coast was evaluated in 2012 • AML - 4/10 and findings published in 201348, with no ratings of Economic Regulatory Environment - 5/10 “Compliant,” with the 40 + 9 Recommendations, • “Largely Compliant” (LC) for 6 Recommendations, • Law Enforcement - 4/10 “Partially Compliant” (PC) for 18 Recommendations, and “Not Compliant” (NC) for 24 • International Co operation 6/10 Recommendations, (with 1 Recommendation 9.3 Law Enforcement/ Financial Intelligence considered “Not Applicable” (NA). A follow up Unit: The Ivory Coast is an Interpol member report was published in November 201449, up rating one Recommendation from PC to LC, but and it’s FIU joined the Egmont Group in 2010. downgrading one Recommendation from PC to NC The Ivory Coast is not active in Financial also. The next Country evaluation, is expected to Information Sharing Partnership’s. start in February 2021. In 2018, according to a GIABA51 the FIU Country Evaluation expected in 2021 received 302 SAR's, of which 53, were passed FATF MER Calendar and used in prosecution’s which were brought to trial. Of all SAR’s, 85% came from the 9.2 Resilience to Organised Crime: banking sector, and the remaining 15% from According to the OCI50 2019, the Ivory Coast is other parts of the financial sector. rated at “Low Resilience” with an overall score is 4.54/6. This is an increase in SAR’s reported from 2015, which was 9352. “Low Resilience” OC Index - 2019 “Less than 1% of estimated criminal proceeds seized” This despite relatively “high levels of Editor FCN international cooperation, a strong judicial 9.4 Asset Seizures system and a robust political leadership in the No reporting of asset seizures has been made fight against organised crime. However, the by the Ivory Coast. Nevertheless it can be country's porous borders and levels of safely assumed and expected that asset corruption need to be addressed to enhance seizures are significantly below 1% of its ability to combat organised crime estimated criminal proceeds. effectively.”

9.5 Freedom: Beyond the definitions ascribed The Ivory Coast ranks 18th/54 in Africa, 6/15 in to Human Trafficking and or Modern Slavery, a West Africa.Ratings by the OC Index for a Ivory Coast - Threat Assessment - 2020 Page 23 of 31 broader concept of freedom is described by 9.6 Governance: Mo Ibrahim Foundations Freedom House’s, Freedom in the World Index, Governance scores, the Ivory Coast at 54.5 / which ranks Countries and their citizens as 100 (African average is 49.9) and 22nd/54 in either, “free” “partly free” or “not free.” The Africa, with an “Increasing Improvement” levels of Freedom have some correlation with rating. corruption and criminality levels and of course 54.5 rating and 22/54 in Africa levels of modern slavery. Mo Ibrahim African Governance Index - 2018

The Ivory Coast is scored at 51/100, and rated It was ranked 45th 10 years ago but is now 53 “partly free ” (where 100 represents most ranked 22nd56. Its improvement has been free). driven mainly by President Alassane Ouattara, who on his resumption in office in 2010 has “Partly Free” Freedom House - 2018 overseen the rebuilding of Ivory Coast’s economy after two civil wars in the last decade. According to the Heritage Foundation’s 2019 Index of Economic Freedom54, the Ivory Ranked 18th worst out of 129 Coast’s economic freedom score is 59.7 Countries, scoring 6.62/10, Basel AML Index 2019 (increase by 0.4%) making its economy the 101/180. 9.7 Basel AML Index: According to the 2019 57 findings, the Ivory Coast has an AML score of “Mostly unfree” 6.62/10 ranked 18th worst from 125 countries. Heritage Foundation’s Index of Economic Freedom- 2019

The index55 reports that, “The right to own and transfer private property is guaranteed, although laws regarding rural land tenure make it prohibitively difficult to do so. Contracts are enforced. The judiciary is ostensibly independent, but judges can be subject to political or financial influence and sometimes fail to base decisions on legal or contractual merits. Corruption in many forms is deeply engrained in both public-sector and private- sector practices.”

Ivory Coast - Threat Assessment - 2020 Page 24 of 31 Section 9 - Resilience & Response Continued

Based on the FCN Sub Saharan Africa Risk Rating Model, the Ivory Coast is rated overall at 45/100 “Moderate - High”, with threats at 50/100 “Moderate” and Response 39/100 “Low - Moderate.”

Ranges for individual components are summarised below, with Low Response - RED, Moderate Response - Amber & Higher Response - Green, (see Section 4 for actual ratings). Key component ratings showing the progress for FATF MER ratings and for OC Index for Resilience, and over time in the Mo Ibrahim African Governance Index and the Basel AML index are also shown.

Ivory Coast - Threat Assessment - 2020 Page 25 of 31 Section 10 - Observations & Recommendations (O&R’s)

Based on this Threat Assessment, the following O & R for IC Financial Institutions: O&R’s are made as follows: Ivorian Fi’s may want to consider whether their • The Country Risk Assessment should be finalised AML/CTF/Proliferation Programmes reflect the and published, and should assess threats and threats identified and/or if changes or vulnerabilities from an Ivory Coast domestic enhancements are needed. Particularly important perspective as well regional threats, in particular are exposures to cocoa and coffee and gold and illicit trade via the largest port in West Africa, but diamonds, and to PEP’s. also imports and exports, including drugs from O & R for Foreign Financial Institutions: South America and illegal wildlife from West Africa to Asia, as well as the role of Corruption. Foreign FI’s that have exposures to the Ivory Coast, from outside the Country may want to consider the • The 4th round Mutuel Evaluation will take some following: time to carry out the review and publish findings,

giving the Ivory Coast, time to close gaps and • PEP’s are likely inherently higher risk, due to high make necessary enhancements. levels of corruption in the Ivory Coast, and the State embedded actor scores (8/10) in the OC • The Ivory Coast Government has made a good Index so FI’s should consider undertaking EDD+ start in taking measures to move away from the & Heightened Monitoring. conflicts of the past .... corruption and under the

former ruling President, though concerns remain • The Ivory Coast can be considered “Mod- High” around sustaining this progress and continuing FC risk from a Foreign FI’s perspective, relative to the positive progression. Act against Human other Countries around the world. The Country is Trafficking including forced labour and child also rated as having an “Improving” trend. forced labour in the cocoa & coffee sectors. • Pending the publication of the MER 4th round • The Ivory Coast should review current priorities Report, it is premature to speculate as far as and resourcing to ensure a renewed focus on the compliance with FATF Recommendations, main criminal markets and those activities that (particularly R-8 NPO’s, R10-CDD, R12-PEP, R13- pose the greatest threats and harms, which CBR, R14-MSB’s, R15-NewTech, R23- Supervision includes acting against illegal mining as well as & R26-FIU, and on Effectiveness (particularly IO3 illegal cocoa plantations and deforestation, as Supervision, IO4-FI (& others) Preventative well as protecting the natural resources available. Measures, IO6-FIU & IO8-Confiscations. Once published these may have an impact on risk • Consider applying KYC and other AML controls ratings for NPO’s, CBR’s, MSB’s, VASP’s and other on importers and exporters, and others involved FinTech’s from IC, and the overall IC Risk Ratings including shippers due to the country’s importance in trade in West Africa, as Kenya is proposing in East Africa.

Ivory Coast - Threat Assessment - 2020 Page 26 of 31 Appendix 1 - Range Matrices by FCN

In Section 8 Illicit funds including “Criminal Proceeds”, estimates for criminal funds in percentage terms and for “Costs of Corruption”, as well as estimates for “Laundering” and “Organised Crime” are set out, based on the inputs and calculations explained below.

1. Criminal Proceeds and Corruption: Table A1 below illustrates how the final estimates for Criminal Proceeds and Costs of Corruption are estimated. By taking the level of Criminality in the OC Index 2019, and the score from TI’s Corruption Index 2019, FCN’s overall Country Risk Rating, and based on the aggregate of these 3 sources a final range estimate for criminal proceeds can be established. For corruption, the three sources are used, but ranges then depend on the level of corruption based on TI’s Corruption Perception Index 2019 score.

Table A1. Range Matrix for Estimating Criminal Proceeds & Corruption by FCN - 2020 - (Very High Rating is 4, High Rating is 3, Moderate Rating is 2 & Low Rating is 1 - with all scores aggregated for OCI Criminality, TI CPI & FCN Country Score

Bottom of the Range % of Top of the Range % of GDP Corruption % of Proceeds If Corruption % of Proceeds If Corruption % of GDP If Score GDP Very High Levels (CPI) High Levels (CPI) Moderate Levels (CPI)

12 10.5% 12.5% 15-20% 10-15% 5%-10%

11 10% 12% 15-20% 10-15% 5%-10%

10 9.5% 11.5 15-20% 10-15% 5%-10%

9 9% 11% 15-20% 10-15% 5%-10% (Includes a V High)

9 8.5% 11.5% 15-20% 10-15% 5%-10% (No V Highs)

8 8% 11% 15-20% 10-15% 5%-10%

7 7.5% 10.5% 15-20% 10-15% 5%-10%

6 7% 10% 15-20% 10-15% 5%-10% (Includes a High)

6 6.5% 9.5% 15-20% 10-15% 5%-10% (No Highs)

5 6% 9% 15-20% 10-15% 5%-10%

4 5.5% 8.5% 15-20% 10-15% 5%-10%

3 5% 8% 15-20% 10-15% 5%-10% (Includes a Moderate)

3 4.5% 7.5% 15-20% 10-15% 5%-10% (no Moderates)

2 4% 7% 15-20% 10-15% 5%-10%

1 3.5% 6.5% 15-20% 10-15% 5%-10%

Note: TI CPI Scores below 50 are rated: 40-49 Moderate to High, 30 to 39, High, below 30 Very High; OCI Criminality Scores are rated: 6 or above at Very High, 5 - 5.9 at High, 4 - 4.9 Moderate and below 4 as Low; FCN Scores are rated: 1-19 - Extremely High, 20 - 29 Very High, 30 - 39 High, 40 - 49 Moderate - High, 50 - 59 Moderate, 60 - 69 Low- Mod, 70 - 79 Low, & 80 - 100. For Costs of Corruption, ranges then depend on the level of corruption based on TI’s Corruption Perception Index 2019 score. For more details on source information for the OC Index, see HERE58, for TI CPI Index see HERE59 and for the results for the Ivory Coast for criminality for corruption and the FCN Country Risk Rating Score see Section 3 above.

Ivory Coast - Threat Assessment - 2020 Page 27 of 31 2. Monies available for Laundering: Table A2 below illustrates how the final estimates for the range for monies available for Laundering was established. The top of the estimated range is 76% of criminal proceeds, based on the findings of the UNODC 2011 Study, which found that of US$2.1 trillion estimated global proceeds, that US$1.6 trillion was available for laundering or 76%, and that most of this this was expected to be available to be laundered via the formal financial sector. Based on the relatively low levels of financial inclusion in most Sub Saharan African Countries compared with the rest of the world, and the size of the shadow and informal economies, as well as the dominance still of cash within Sub Saharan economies, the estimates available for laundering through the formal financial sector have been assessed with these factors in mind based on the range estimates set out below, from sources estimating bank account and mobile money penetration. Ivory Coast is rated “Very Low.” For more details on source information on Financial Access, see HERE60.

Table A2. Ratings Range Matrix for Laundering by FCN - 2020

Financial Access Range % for Laundering Financial Access Range % for Laundering Criminal Proceeds Criminal Proceeds

V Low Access Levels 40-50 Moderate Access Levels 60-70 < 30% bank accounts AND >40% - 50% bank accounts <30% mobile money OR >40% - 50% mobile money OR vice versa

Lower Access Levels 50-60 Higher Access Levels 70-76 >30% - 40% bank accounts > 50% bank accounts OR OR >30% - 40% mobile money > 50% mobile money

3. Criminal Proceeds Involving Organised Crime: Table A3 below illustrates how the final estimates for the range for criminal proceeds involving Organised Crime was established. The top of the estimated range is 46% of criminal proceeds, based on the findings of the UNODC 2011 Study, which found that of US$2.1 trillion organised crime were involved in US$960 million or approx 46%. Table A takes the different scores for organised crime in Sub Saharan African Countries reported by the OC Index and presents an estimate or range as a % of criminal proceeds, established as set out in Appendix 1 Section 1 above. For more details on OC information, see HERE61.

Table A3. Ratings Range Matrix for Involvement by Organised Crime by FCN - 2020

Criminal Actors Score in OC Index Range % for OC Financial Criminal Actors Score in OC Index Range % for OC Involvement Involvement

Below 4 /10 in OC Index 2019 22-24 Rated 6 - 6.5/10 in OC Index 2019 32-34

Rated 4 - 4.5/10 in OC Index 2019 24- 26 Rated 6.5 -7/10 in OC Index 2019 34-36

Rated 4.5-5/10 in OC Index 2019 26-28 Rated 7-7.5/10 in OC Index 2019 36-38

Rated 5-5.5/10 in OC Index 2019 28-30 Rated 7.5-8/10 in OC Index 2019 38-40

Rated 5.5-6/10 in OC Index 2019 30-32 Rated 8/10 in OC Index 2019 or above 40-46

Ivory Coast - Threat Assessment - 2020 Page 28 of 31 Message from the Editor - FCN

This Country Threat Assessment focuses on the financial crime threats and responses and is both a stand-alone publication, but can also be read in conjunction with the Global Threat Assessment, published in 2019 and the Sub Saharan Threat Assessment published in 2020. The Sub Saharan Threat Assessment has been supplemented by this Threat Assessment as well as for other Countries in Sub Saharan Africa. The individual Country Threat Assessments have been co created with dedicated financial crime fighters from the Countries covered and or with the help of professionals familiar with the Country, based on a consistent approach researching available open source information. Judgement is applied in deciding what to include and what to emphasise. Each Country Assessment follows the same structure and includes the same main sources, usually over 50 sources from important and credible agencies, in the form of reports, papers and or ratings. The Country Threat Assessments include the results from the FCN Sub Saharan Africa 2020 Risk Rating Scorecard which includes a significant number of these sources to aggregate the threats and the responses to derive a final rating and a final ranking.

More Financial Crime Materials from FCN

Global Threat Phase 1 - 19 Country Sub Saharan Africa Sub Saharan Africa Assessment by FCN - Threat Assessments Country Risk Ratings Threat Assessment by 2019 by FCN - 2020 FCN - 2020

Available at: https://thefinancialcrimenews.com For Subscription for Commercial Businesses / Free to NGO’s and Policy Makers Or Contact the Editor: [email protected]

Acknowledgements: Thanks and appreciation to a number of colleagues and collaborators who freely gave their time, to research, comment and provide advice in connection with this Ivory Coast Threat Assessment, including: Hans Peter Bauer, Ursula M’Crystal, Victoria Meyer, Bruce Viney and Andrew Williams.

Information to Note: The information, provided in this Country Threat Assessment is designed to help those involved in combating financial crime. The Editor (John Cusack) takes full and sole responsibility for the contents of this document, including any opinions, observations or recommendations, but does not take responsibility for referenced materials, that are the responsibility of the authors and publishers as appropriate. References are provided for information purposes and do not constitute endorsement of any information. readers should be aware that website references listed may change. Ownership and all rights are with Metriqa Limited.

Author(s) & Editor Authors are John Cusack with Tatiana Akra. The Editor is John Cusack. John Cusack is a leading financial crime fighter, Editor of the Financial Crime News, former Global MLRO at UBS and Standard Chartered Bank, Two time Co Chair of the Wolfsberg Group (to end 2019), and adviser to a number of financial institutions, Regtech Providers, and engaged with NGO’s combatting wildlife and human trafficking. Tatiana Akra is a West African based financial crime fighter, Regional Compliance Project Manager for Orange Money in the Ivory Coast, based in Abidjan.Tatiana, worked for 1 year at Atlantic Business International (ABI) as Senior Compliance Specialist. Prior to this, she worked 9 years as legal and Compliance Officer for United Bank for Africa in Abidjan

Ivory Coast - Threat Assessment - 2020 Page 29 of 31 Endnotes: 1 See: https://epi.yale.edu/epi-indicator-report/EPI 2 See: https://datareportal.com/reports/digital-2020-cote-divoire 3 See: https://www.state.gov/2020-incsr-volume-ii-money-laundering-and-financial-crimes-as-submitted-to-congress/ 4 See: https://bm.usconsulate.gov/wp-content/uploads/sites/121/2016/11/INSCR.pdf 5 See: https://tradingeconomics.com/ivory-coast/corruption-index 6 See: https://www.traceinternational.org/trace-matrix 7 See: https://afrobarometer.org/sites/default/files/publications/Publications%20conjointes/partenaires/ab_r7_global_corruption_barometer_report.pdf 8 See: https://ocindex.net/country/cote-divoire/ 9 See: https://ocindex.net/country/cote-divoire/ 10 See: https://ocindex.net/country/cote-divoire/ 11 See: http://www.mightyearth.org/wp-content/uploads/2017/09/chocolates_dark_secret_english_web.pdf/ 12 See: https://ocindex.net/country/cote-divoire/ 13 See: http://iuufishingindex.net/profile/cote-divoire 14 See: https://ocindex.net/country/cote-divoire/ 15 See: https://issafrica.org/iss-today/is-cote-divoire-becoming-a-wildlife-trafficking-hotspot 16 See: https://www.nst.com.my/world/2018/01/328815/ivory-coast-seizes-huge-haul-elephant-tusks-and-pangolin-scales 17 See: http://www.mightyearth.org/wp-content/uploads/2017/09/chocolates_dark_secret_english_web.pdf/ 18 See: http://wedocs.unep.org/bitstream/handle/20.500.11822/9835/-Côte_d’Ivoire_Post-Conflict_Environmental_Assessment-2015Côte_d’Ivoire_Post- Conflict_Environmental_Assessment.pdf.pdf?sequence=6&isAllowed=y 19 See: https://ourworldindata.org/air-pollution 20 See: https://borgenproject.org/5-facts-water-quality-in-cote-divoire/ 21 See: https://www.globalslaveryindex.org/2018/data/country-data/cote-d-ivoire/ 22 See: https://www.ilo.org/wcmsp5/groups/public/---ed_norm/---declaration/documents/publication/wcms_243391.pdf 23 See: https://www.state.gov/wp-content/uploads/2019/06/2019-Trafficking-in-Persons-Report.pdf 24 See: https://en.wikipedia.org/wiki/Child_labour_in_cocoa_production 25 See: https://www.state.gov/reports/2019-trafficking-in-persons-report-2/cote-divoire/ 26 See: https://www.state.gov/reports/2019-trafficking-in-persons-report-2/cote-divoire/ 27 See: https://www.dol.gov/agencies/ilab/resources/reports/child-labor/sub-saharan-africa 28 See: https://ocindex.net/country/cote-divoire/ 29 See: https://www.un.org/press/en/2019/gadis3635.doc.htm 30 See: https://ocindex.net/country/cote-divoire/ 31 See: http://koaci.com/cote-divoire-marche-noir-adjame-roxy-enfin-demantele-tonnes-faux-medicaments-saisis-109034.html 32 See: http://www.mixedmigration.org/wp-content/uploads/2019/10/Mixed-Migration-Review-2019.pdf 33 See: https://www.bbc.com/news/business-25735305 34 See: https://au.int/sites/default/files/documents/37326-doc-k-15353_au_illicit_financial_flows_devv10_electronic.pdf 35 See: https://isis-online.org/uploads/isis-reports/documents/ThePeddlingPerilIndex2019_POD.pdf 36 See: https://sanctionssearch.ofac.treas.gov 37 See: https://www.state.gov/wp-content/uploads/2019/11/Country-Reports-on-Terrorism-2018-FINAL.pdf 38 See: https://bm.usconsulate.gov/wp-content/uploads/sites/121/2016/11/INSCR.pdf 39 See: https://www.counterextremism.com/countries/cote-d-ivoire 40 See: https://www.counterextremism.com/countries/cote-d-ivoire 41 See: https://au.int/sites/default/files/documents/37326-doc-k-15353_au_illicit_financial_flows_devv10_electronic.pdf 42 See: https://secureservercdn.net/45.40.149.159/34n.8bd.myftpupload.com/wp-content/uploads/2020/03/GFI-Trade-IFF-Report-2020-Final.pdf?time=1583530239 43 See: https://gfintegrity.org/gftrade/ 44 See: Appendix 1 45 See: Appendix 1 46 See: Appendix 1 47 See: Appendix 1 48 See: https://www.giaba.org/reports/mutual-evaluation/Cote%20d'Ivoire.html 49 See: https://www.giaba.org/reports/mutual-evaluation/Cote%20d'Ivoire.html 50 See: https://ocindex.net/country/cote-divoire/ 51 See: https://www.giaba.org/media/f/1071_FR_RESUME%20DES%20RAPPORTS%20PAYS%202018.pdf 52 See: https://bm.usconsulate.gov/wp-content/uploads/sites/121/2016/11/INSCR.pdf 53 See: https://freedomhouse.org/report/countries-world-freedom-2019 54 See: https://www.heritage.org/index/country/cotedivoire 55 See: https://www.heritage.org/index/country/cotedivoire 56 See: http://venturesafrica.com/mo-ibrahim-index-of-governance-reports-that-africa-still-needs-to-do-more-regarding-youth-employment/ 57 See: https://www.baselgovernance.org/sites/default/files/2019-08/Basel%20AML%20Index%202019.pdf 58 See: https://ocindex.net 59 See: https://www.transparency.org/cpi2019?/news/feature/cpi-2019 60 See: https://datareportal.com/library 61 See: https://ocindex.net

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