Ivory Coast - Threat Assessment 2020 - Page of 1 - Financial Crime News

Ivory Coast - Threat Assessment - 2020 Page 1 of 31

Sanctions & Terrorism: No Comprehensive
 Ivory Coast Sanctions against the Country, though some
 former senior leaders are still designated. For
 Section 1 - Executive Summary Proliferation Tier 3 PPI (Proliferation) Index,
 refl ects 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 Traffi cking (7/10), Applicable” (NA). The next evaluation, is
Wildlife Crime (6.5/10), Drug Traffi cking 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 Mafi a 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 Traffi cking 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: Yamoussoukro/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, fi sh 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 Proceeds / Laundering
 (Average Country Score is 32 - SSA )

 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 Ghana &
 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
 2 Goods Piracy
Human & Arms Trafficking, Lebanon (Terrorism
 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 - "

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

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 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 fi nal 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
offi cial language. In December 1999, a military million in exports in 2016.
coup overthrew the government, with Laurent
Gbagbo 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, Alassane Ouattara 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 fi nancial profi le2
 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 OECD - Global Forum Not Yet Reviewed FATF Standards MER to start in 2020
 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
signifi cant 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
Corruption Perception Index 2019 (CPI - 2019),
 “high risk” for corruption
 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

 2010 2013 2016 2019
 published in 20197, (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
 further afield. Most of the illicit economies
 Synthetics Wildlife HT Mining Logging Arms Cannabis People Smugg

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 fi shing grounds. These
has one of the highest deforestation rates in fi shing grounds still contain large stocks of
Africa, and although most of the forest loss is a fi sh, 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. Trafi gura, was fi ned 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 Trafi gura 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 fi nally 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.”

5.6 Human Trafficking: According to the
 Forced labour (including child labour)
 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
estimates22, 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 confl icts, it has experienced an increase 4.0
 3.0
in the fl ow of arms, with arms traffi cking 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 diffi cult 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 fi rst 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 signifi cant 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 offi cials 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

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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 identifi ed 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 identifi ed. 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

 Criminal activities such as:
 (Terrorism AQIM / AD) undertaken, including when purchasing high
 Other FI’s such as Bureau
 Illegal Logging & Mining,
 Human & Arms Trafficking,
 de-Change, MSB’s MMO’s
 Lebanon (Terrorism
 value assets, such as real estate, vehicles, gold
 DNFBP’s including Finance - via support for
 Wildlife Crime & Drug
 precious metals and Hezbollah) and gems.
 Trafficking, & Smuggling stones dealers
 along with Corruption (e.g Major Export / Import
 PEP’s) which also helps Informal Sectors Partner Countries (Trade
 Mispricing and IFF’s -
 7.3 Trade Based Money Laundering: Whilst
 facilitate these crimes &
 particularly mining and
 Tax Evasion as a high risk extraction sectors) cash based money laundering is therefore the
 concern also.
 Latin America (drugs) & principle and likely most popular method, for
 SE Asia (wildlife)
 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 signifi cant.

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
 14% Forced Labour Theft
 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
Global Financial Integrity42 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
 Goods Piracy
 2
 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
common method for Theft
 3

 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 fi ndings published in 201348, with no ratings of
“Compliant,” with the 40 + 9 Recommendations, • Economic Regulatory Environment - 5/10

“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 defi nitions ascribed
The Ivory Coast ranks 18th/54 in Africa, 6/15 in
 to Human Traffi cking 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
levels of modern slavery.
 54.5 rating and 22/54 in Africa
 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
“partly free53” (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 fi nal 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 fi nal 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 fi nal 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 fi ndings 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 fi nancial sector. Based on the relatively low levels
 of fi nancial 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 fi nancial 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
 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 fi nal
 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 fi ndings 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

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