KYB in Mali: Business Verification Requirements and Compliance Risks

Know Your Business (KYB) requirements in Mali form a core part of the country’s framework for combating money laundering, terrorist financing, and proliferation financing (AML/CFT/CPF). While KYC focuses on individuals, KYB obligations are designed to ensure transparency around legal entities, their ownership structures, and the legitimacy of their activities.

For banks, fintechs, and payment service providers onboarding corporate customers in Mali, robust KYB processes are essential to managing regulatory risk and maintaining access to regional and international financial systems. Solutions such as VOVE ID can support structured business and beneficial ownership verification aligned with regional requirements.

Regulatory framework applicable to KYB

The AML/CFT/CPF framework applicable in Mali is primarily based on:

• The new WAEMU Uniform Law on AML/CFT/CPF, adopted by the WAEMU Council of Ministers in 2023, transposing updated FATF standards and establishing harmonised due diligence and transparency requirements across member states;
• National implementing measures, adopted as part of the ongoing transposition of the 2023 Uniform Law, in line with WAEMU timelines and regional supervisory expectations;
• Regulations, instructions, and supervisory guidance issued by the Central Bank of West African States (BCEAO).

Supervisory oversight and financial intelligence functions are carried out by CENTIF-Mali, in coordination with national authorities and the BCEAO.

In June 2025, Mali was removed from the Financial Action Task Force (FATF) list of jurisdictions under increased monitoring. This has reinforced expectations around effective KYB and AML controls, particularly for institutions relying on correspondent banking and cross-border financial relationships.

What KYB means in the Malian context

KYB refers to the procedures used to identify, verify, and assess legal entities before establishing and maintaining a business relationship. In Mali, regulated entities are required to:

1. Verify the legal existence and registration of a business;
2. Identify and verify ultimate beneficial owners (UBOs);
3. Understand the nature and purpose of the business relationship;
4. Assess the entity’s risk profile and apply appropriate controls.

KYB obligations apply not only at onboarding, but throughout the lifecycle of the business relationship.

Core KYB requirements in Mali

Business identification and verification

Before onboarding a corporate customer, institutions must collect and verify information such as:

• Legal name and commercial registration details;
• Articles of incorporation or equivalent constitutional documents;
• Registered address and principal place of business;
• Tax identification number, where applicable;
• Details of directors, legal representatives, and authorised signatories.

Verification should rely on reliable and independent sources, including official registries and certified documentation.

Ultimate Beneficial Ownership (UBO) transparency

In line with WAEMU standards, institutions must identify the natural persons who ultimately own or control a legal entity.

As a general rule, this includes individuals who:

• Own or control 25% or more of the entity, directly or indirectly;
• Exercise control through voting rights or other means;
• Act as senior managing officials where no individual meets the ownership threshold.

Accurate UBO identification is a critical pillar of KYB, particularly for entities with layered or cross-border ownership structures. Dedicated KYB tools such as VOVE ID can help standardise UBO checks and ownership analysis across jurisdictions.

Risk-based approach and enhanced KYB

KYB obligations in Mali follow a risk-based approach, requiring enhanced scrutiny for higher-risk corporate customers.

Higher-risk categories may include:

• Companies operating in gold mining and extractive industries, including artisanal mining;
• Businesses with significant cash-based operations;
• Entities involved in humanitarian aid, NGOs, or donor-funded activities;
• Companies where politically exposed persons (PEPs) are present within ownership or control structures;
• Businesses engaged in cross-border trade involving higher-risk jurisdictions;
• Complex or opaque ownership arrangements.

Where higher risk is identified, Enhanced Due Diligence (EDD) may involve additional documentation, deeper ownership analysis, and senior management approval.

Ongoing KYB reviews

While KYB focuses on business verification rather than transaction monitoring, regulated entities are required to:

• Keep business and ownership information up to date;
• Reassess risk following material changes (ownership, activity, geography);
• Ensure consistency between the customer’s profile and its declared operations.

Periodic KYB reviews are particularly important for higher-risk sectors and fast-growing companies.

Record-keeping obligations

KYB-related records (including business documents, UBO information, and risk assessments) must be retained for at least 10 years after the end of the business relationship, in line with WAEMU and national requirements.

Appropriate safeguards must be implemented to protect sensitive corporate and personal data.

Penalties and supervisory impact

Failure to comply with KYB obligations may result in:

• Administrative sanctions and financial penalties;
• Supervisory remediation measures;
• Suspension or withdrawal of licenses in serious cases;
• Criminal liability where intentional violations are established.

In addition to national enforcement, the BCEAO may apply sanctions at the WAEMU level, meaning deficiencies in KYB controls in Mali can affect regional operations, lead to reputational damage, and result in restrictions imposed by international correspondent banks.

Conclusion

For companies onboarding corporate customers in Mali, KYB is a critical pillar of AML/CFT/CPF compliance. Transparent ownership structures, accurate business verification, and risk-based controls help reduce exposure to financial crime and support sustainable growth across the WAEMU region.

By supporting structured KYB workflows and UBO verification, VOVE ID helps teams streamline business onboarding while remaining aligned with Malian and regional regulatory expectations.