- within International Law, Environment and Finance and Banking topic(s)
The Parliament of Rwanda enacted an amendment to Law No. 045/2021 which governs the Financial Intelligence Centre, ("FIC"), marking a significant enhancement of the country's anti-money laundering and counter-terrorist financing ("AML/CFT") framework. The amendment, which was passed by the Chamber of Deputies on 9 January 2025 and subsequently came into effect, expanded the FIC's powers, heightened obligations for reporting entities, and promoted stronger international cooperation.
Key changes
Key changes introduced by the amendment include an expansion of
the FIC's authority, granting it broader powers to monitor,
request and analyse information on suspicious transactions. The FIC
now has increased ability to coordinate with domestic regulators,
law enforcement and foreign counterparts to address complex and
cross-border cases.
Reporting obligations for financial institutions and designated
non-financial businesses and professions
("DNFBPs") have been heightened,
requiring enhanced due diligence for higher-risk clients and
scenarios, more rigorous know-your-customer
("KYC") requirements in specified
contexts and continuous, risk-based transaction monitoring to
detect unusual or suspicious activity.
The amendment also introduced higher monetary fines and stricter administrative sanctions for non-compliance, aiming to deter misconduct and foster a culture of compliance. Additionally, the law enables measures to facilitate faster mutual legal assistance and information sharing with foreign authorities and financial intelligence units, strengthening Rwanda's international cooperation in combating financial crime.
Local reporting entities and foreign companies
The amendment also aligns Rwanda's regulatory framework with global standards, such as those set by the Financial Action Task Force ("FATF"), reducing opportunities for illicit finance to flow through local markets.
For reporting entities, these changes have resulted in more detailed expectations around risk assessment, customer identification and verification (including beneficial ownership), ongoing monitoring, and timely suspicious transaction reporting. Record-keeping, data quality, and auditability have become central to compliance, with the potential for more frequent inspections or spot-checks by the FIC.
Foreign companies operating in Rwanda should be aware that cross-border activity and higher-risk customer segments now attract increased monitoring and potential information requests. Multijurisdictional firms must ensure that their Rwandan operations meet local requirements while maintaining consistency with global AML/CFT frameworks. The expanded international information sharing enabled by the amendment has also increased the speed and reach of cross-border inquiries and enforcement actions.
Practical steps
- Institutions should immediately review their anti-financial
crime frameworks and work towards compliance by:
Conducting gap assessments: mapping current AML/CFT policies, procedures, and controls against anticipated enhancements (Enhanced Due Diligence ("EDD") triggers, KYC depth, ongoing monitoring thresholds, Suspicious Transaction Reporting ("STR") processes, record retention) - Strengthening governance: confirm board/senior management oversight, update enterprise‑wide risk assessments, and ensure clear lines of accountability for AML/CFT.
- Increasing monitoring: upgrade transaction monitoring, screening tools, alert handling, and model governance to reflect higher‑risk typologies and local obligations.
- Enhancing customer due diligence: refresh KYC files, verify beneficial ownership, and document risk‑rating rationales, with special focus on high‑risk customers and complex structures.
- Conducting training and testing: rolling out targeted training for front-line, compliance, and audit teams; conducting thematic reviews and quality assurance on STRs and KYC/EDD files.
- Preparing for supervision: organise documentation for potential FIC audits, including policy inventories, risk assessments, customer files, and monitoring/adverse media records.
Conclusion
The amendment to Law No. 045/2021 marks a decisive advancement in Rwanda's commitment to international AML/CFT standards, ushering in a new era of regulatory rigor and supervisory expectations. Both domestic and foreign organisations operating in Rwanda should review and strengthen their risk-based controls, compliance documentation, and operational readiness to meet these heightened requirements.
As the regulatory landscape continues to evolve, it is essential to closely monitor forthcoming legislative texts and regulatory guidance, which will clarify detailed obligations, implementation timelines, and transitional measures, including the scope of enhanced due diligence, reporting thresholds, and data retention standards. It is critical to proactively ensure compliance in Rwanda's financial environment.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
