Jurisdictions

In short

A jurisdiction is everything that differs between countries, kept as data rather than code:

• the financial intelligence unit (FIU), the format reports are filed in, and its codes;
• the cash transaction report (CTR) thresholds;
• the national identifiers (Ghana Card, BVN, NIN…) and what a valid one looks like;
• the FATF high-risk lists;
• the sanctions lists a workspace screens against until it chooses its own;
• the minimum record-keeping period;
• the regulators;
• the rule packs it recommends for each kind of institution;
• and, for every value that comes from research rather than an official source, a note to confirm it with the regulator.

Each workspace follows one jurisdiction. It sets the defaults for reporting and identifier checks, and decides which rule packs the rule library offers first. It never changes your transactions, alerts or cases, and it never overrides a reporting value you have already saved.

Confirm every value before you go live

Thresholds, report codes and identifier formats come from SpeculaPro’s research of each country’s laws and circulars. Each jurisdiction lists the values still to confirm. Check every one with your FIU and regulator, and with your MLRO, before relying on it.

The jurisdictions available

Code	Jurisdiction	Currency	FIU	Report format	Cash report (CTR)	Keep records
gh	Ghana	GHS	Financial Intelligence Centre (FIC)	goAML	GHS 50,000 or more, same-day cash adds up	5 years
ng	Nigeria	NGN	Nigerian Financial Intelligence Unit (NFIU)	goAML	Above NGN 5,000,000 (individual) or NGN 10,000,000 (business), per transaction; an amount equal to the threshold isn’t reported	5 years
bj	Benin	XOF	CENTIF Bénin	CENTIF declaration	XOF 15,000,000 or more, linked operations add up	10 years
bf	Burkina Faso	XOF	CENTIF Burkina Faso	CENTIF declaration	XOF 15,000,000 or more, linked operations add up	10 years
ci	Côte d’Ivoire	XOF	CENTIF-CI	CENTIF declaration	XOF 15,000,000 or more, linked operations add up	10 years
gw	Guinea-Bissau	XOF	CENTIF Guinée-Bissau	CENTIF declaration	XOF 15,000,000 or more, linked operations add up	10 years
ml	Mali	XOF	CENTIF Mali	CENTIF declaration	XOF 15,000,000 or more, linked operations add up	10 years
ne	Niger	XOF	CENTIF Niger	CENTIF declaration	XOF 15,000,000 or more, linked operations add up	10 years
sn	Senegal	XOF	CENTIF Sénégal	CENTIF declaration	XOF 15,000,000 or more, linked operations add up	10 years
tg	Togo	XOF	CENTIF Togo	CENTIF declaration	XOF 15,000,000 or more, linked operations add up	10 years
sl	Sierra Leone	SLE	Financial Intelligence Agency (FIA)	goAML (assumed)	SLE 30,000 or more, same-day cash adds up. To verify with counsel	5 years
lr	Liberia	LRD	Financial Intelligence Agency (FIA)	goAML (assumed)	LRD 1,000,000 or more (individual) or LRD 2,000,000 (business), same-day cash adds up. To verify with counsel	5 years
gm	The Gambia	GMD	Financial Intelligence Unit (FIU)	goAML (assumed)	GMD 450,000 or more (individual) or GMD 2,000,000 (business), same-day cash adds up. To verify with counsel	5 years
gn	Guinea	GNF	CENTIF Guinée	CENTIF declaration	GNF 100,000,000 or more, linked operations add up: a working value, not a confirmed figure. To verify with counsel	10 years
ke	Kenya	KES	Financial Reporting Centre (FRC)	goAML	KES 1,300,000 or more (USD 10,000), same-day cash adds up. To verify with counsel	7 years
global	Other country (FATF baseline)	Your workspace’s	Your national FIU	goAML (generic codes)	None: no CTR is drafted until you set your own thresholds	5 years

The eight UEMOA states share the rules of the West African Economic and Monetary Union (uemoa): the BCEAO’s thresholds, the francs CFA, French as the default language and the CENTIF reporting codes (DOS for a suspicious transaction, DTE for cash; DSTE in Côte d’Ivoire). Each state adds its own CENTIF, time zone and identifiers. uemoa itself is a region, which no workspace can pick: choose your country.

Other country is the fallback for a country without its own definition: the FATF baseline, with goAML’s generic codes, which you replace with your FIU’s. It defines no cash reporting threshold, so cash transaction reports stay off, and can’t be switched on, until you enter your own thresholds. See When no threshold is set.

Sierra Leone, Liberia, The Gambia, Guinea and Kenya: nothing is confirmed

For these five jurisdictions, every threshold, deadline and detail about the financial intelligence unit comes from SpeculaPro’s research of public sources and is marked to verify with counsel in the definition. None has been confirmed by a regulator or reviewed by a lawyer, and nothing here is legal advice. Verify each value with your legal counsel and confirm it with the regulator before you rely on it, and before you switch on cash transaction report drafting. See The five newest jurisdictions.

The CENTIF declaration’s layout isn’t confirmed

No UEMOA CENTIF is known to use goAML: Senegal files through e-Delta, Côte d’Ivoire through Mon Espace CENTIF, and the others are unconfirmed. Reports for these states, and for Guinea, export as a CENTIF declaration: a French form to print, sign and file, with the same content as an XML file. Its layout and XML schema are SpeculaPro’s own, built from the content of the model declaration form in the UEMOA uniform law. No CENTIF has confirmed that it accepts them. This is not legal advice: confirm with counsel and your CENTIF before your first filing. See Filing with a CENTIF.

The five newest jurisdictions

Sierra Leone, Liberia, The Gambia, Guinea and Kenya each have a definition and two rule packs. Read this table as what SpeculaPro assumes until you tell it otherwise, not as a statement of the law. This is not legal advice; confirm every cell with counsel and the regulator.

	Sierra Leone (sl)	Liberia (lr)	The Gambia (gm)	Guinea (gn)	Kenya (ke)
FIU, as named in the definition	Financial Intelligence Agency of Sierra Leone (FIA); the name and web address are to verify	Financial Intelligence Agency of Liberia (FIA)	Financial Intelligence Unit of The Gambia (FIU)	Cellule Nationale de Traitement des Informations Financières (CENTIF)	Financial Reporting Centre (FRC)
How reports are filed	goAML is assumed	goAML is assumed; the FIA has also taken reports on its own templates	goAML is assumed	No machine format was found: reports export as the French CENTIF declaration, whose layout is unconfirmed	goAML
Report codes	STR, CTR (goAML’s generic codes)	STR, CTR	STR, CTR	DOS, DTE	STR, CTR
Cash report threshold	SLE 30,000 for individuals and businesses (SLE 100,000 is sometimes cited for businesses; the lower is used)	LRD 1,000,000 (individual) and LRD 2,000,000 (business): USD 5,000 and USD 10,000 at about LRD 200 to the dollar	GMD 450,000 (individual) and GMD 2,000,000 (business)	GNF 100,000,000: a working value close to the FATF’s USD/EUR 15,000, not a figure from Guinean law	KES 1,300,000: USD 10,000 at about KES 130 to the dollar (USD 15,000 after a 2023 amendment is reported; the lower is used)
Cash equal to the threshold	Reported (at or above)	Reported	Reported	Reported	Reported
Same-day cash adds up	Yes (assumed)	Yes (assumed)	Yes (assumed)	Yes (assumed)	Yes (assumed)
STR deadline the definition notes	2 days after the suspicion is formed	Promptly; 3 working days is a working assumption	Promptly; 3 working days is a working assumption	Without delay	2 days after the suspicion arises
Keep records	5 years	5 years	5 years	10 years	7 years
Identifier formats checked	None	None	None	RCCM number only	National ID number, passport, KRA PIN, Business Registration Service number
Default language	English	English	English	French	English
Rule packs	sl-psp, sl-bank	lr-psp, lr-bank	gm-psp, gm-bank	gn-emi, gn-bank	ke-psp, ke-bank

What else to know:

• The STR deadline is a note, not a timer. It appears among the values to confirm in the Jurisdiction panel and in the definition’s notes; SpeculaPro doesn’t count down or enforce it.
• Thresholds written in US dollars. Liberia’s and Kenya’s cash thresholds are understood to be set in US dollars, and the definitions restate them in the local currency at a fixed rate. Keep the amounts under Settings → Reporting in line with the central bank’s rate. The panel shows the US-dollar figure too (USD 5,000 for Liberia, USD 10,000 for Kenya).
• Liberia has two currencies. The definition is for a workspace whose base currency is the Liberian dollar. A workspace that keeps its books in US dollars follows Other country instead, by itself: enter your own thresholds there.
• Sierra Leone’s amounts are in new leones (SLE), which replaced the old leone at 1,000 to 1 in 2022. Legal texts written before then quote old leones.
• Guinea is not a UEMOA state. It has its own currency (the Guinean franc, which has no minor unit), central bank and law. It only shares the CENTIF declaration as its export format, until its CENTIF confirms how it takes reports.
• Sanctions lists. All five screen against the baseline lists by default (un-sc, us-ofac-sdn, us-ofac-cons, eu-fsf, gb-uksl). None adds a domestic list: Kenya’s FRC list (ke-frc) exists as a screening list but is not on by default; switch it on under Settings → Screening if you need it.
• Shared packs install rough local amounts. From core 1.4.0, fraud 1.4.0 and global-fatf 1.2.0, these packs install default amounts in SLE, LRD, GMD, GNF and KES: the US dollar figures scaled at a rough exchange rate and rounded, with the cash reporting threshold above in the large-cash and structuring rules. Review every amount before you enable a rule. See Packs written in another currency.
• Data protection. Each definition notes the country’s data-protection position as far as research found it, itself to verify with counsel. It is a note only: it doesn’t change the Privacy area’s retention periods or deadlines.

The packs are described rule by rule in Sierra Leone, Liberia, The Gambia, Guinea and Kenya.

What a jurisdiction changes

Area	What the jurisdiction sets
Reporting settings	The defaults: the report format (goAML or the CENTIF file), the report codes, the lookup codes, the identifier type codes and the country of the reporting location. A value you have saved keeps its saved value
Cash transaction reports	The default thresholds for individuals and businesses, in your currency; whether cash equal to the threshold is reported or only cash above it; and whether a customer’s same-day cash adds up. A jurisdiction with no threshold means no CTRs until you set one
Identifier checks	When customers are sent in, each national identifier is checked against the jurisdiction’s format for its type (see below)
Rule library	Packs for your jurisdiction come first, under Your jurisdiction: …, marked Recommended for your kind of institution. Packs for other countries are folded away under Other jurisdictions
The Jurisdiction panel	Shows the FIU, cash and foreign transfer thresholds, record keeping, identifiers, regulators, the FATF lists with their date, and the values to confirm

Changing the jurisdiction doesn’t install or remove rule packs, change rules that are running, or touch past reports.

Identifier checks

The jurisdiction knows the format of each national identifier, for example 11 digits for a Nigerian BVN or NIN, or GHA-123456789-0 for a Ghana Card. When a customer arrives through the ingest API, a file import or a file drop, its national_id is checked against the format for its type. Identifier checks decides what happens to a value that doesn’t fit:

Setting	What happens
Warn: accept, and flag values that don’t fit (the default)	The customer is accepted, and the item’s result carries a warning such as national_id: bvn doesn’t look like a valid Bank Verification Number (BVN) (expected a value like 22123456789)
Reject records whose identifier doesn’t fit	The customer is rejected with that message as its error
Don’t check identifiers	No check

Types the jurisdiction has no format for, and the type other, are never checked. Start with Warn, look at the warnings for a few days, and only then consider Reject.

How to see or change your jurisdiction

You need settings.manage (by default, administrators).

1. Select Settings, then the Workspace tab.

2. Scroll to Country rules and reporting.

   

3. Open values to confirm with the regulator to see what still needs checking.

4. To change it, choose another Jurisdiction or Identifier checks value. The hint changes to Changing the jurisdiction goes for approval when your workspace requires it. Reporting values you already saved are kept.

5. Select Save changes.

The list offers only the jurisdictions in your workspace’s base currency, plus Other country. A cedi workspace can follow Ghana or Other country, not Nigeria: every amount and threshold is stored in the base currency, which can’t change after the workspace is created.

A change may need a second person

Changing the jurisdiction or the identifier checks is the Jurisdiction change type (settings.jurisdiction), on by default. Once two people can approve workspace settings, the change is sent to them as a request instead of applying straight away. See Approvals.

Workspaces created before jurisdictions

A workspace that has never picked a jurisdiction follows the one for its country, when its base currency is that jurisdiction’s currency: Ghana for a cedi workspace in Ghana, Liberia for a Liberian-dollar workspace in Liberia. In every other case it follows Other country: a country without a definition, or a workspace that keeps its books in another currency, such as a US-dollar workspace in Liberia. A definition’s thresholds are amounts in its own currency, so SpeculaPro never reads them in another one. Nothing changes for the workspace until an administrator picks a jurisdiction. The panel shows the one it follows as selected.

The base currency decides the reporting and rules side only. The default sanctions lists still follow the workspace’s country, whatever its currency.

Existing workspaces in the five newest countries

A workspace whose country is Sierra Leone, Liberia, The Gambia, Guinea or Kenya, whose base currency is that country’s, and that never picked a jurisdiction, followed Other country until its country had a definition. After the upgrade that adds them it follows its country’s definition. Reporting values you already saved are kept. Values you never saved now take the country’s defaults, including its unverified cash thresholds, so cash transaction reports can be switched on where before they couldn’t. Review Settings → Reporting after upgrading, and verify the thresholds with counsel before you switch drafting on.

Workspaces whose currency isn’t their country’s

Before this rule, a workspace that never picked a jurisdiction took its country’s thresholds whatever its base currency: a US-dollar workspace in Ghana read GHS 50,000 as USD 50,000. Such a workspace now follows Other country, which sets no cash reporting threshold. What happens to it on upgrade depends on whether it was drafting cash transaction reports:

• Drafting was on and it never saved its own thresholds. The upgrade writes the figures it was using into its settings, unchanged, so drafting does not stop. They are still a number in the wrong currency (the country’s figure read in the workspace’s currency): replace both thresholds under Settings → Reporting with the right amounts. A red warning stands there until a threshold is changed and saved; see Reporting settings.
• Drafting was off. Nothing is written. It has no threshold, and drafting can’t be switched on until you enter both.

Check each such workspace after upgrading. If drafting is ever on with no threshold, the Reporting tab shows a red warning and the worker logs an error. See When no threshold is set.

For operators: the command line

Creating a workspace for a jurisdiction. speculapro tenant create takes --jurisdiction. The jurisdiction’s currency, time zone and default language fill in whatever you don’t give:

speculapro tenant create --slug kweku-ng --name "Kweku Pay Nigeria" --kind psp \
  --jurisdiction ng --admin-email [email protected] --admin-name "Ada Obi"

This makes a naira workspace on Lagos time. Without --jurisdiction, the country decides (--country, Ghana by default). A region such as uemoa is refused: pick a member state. A jurisdiction whose currency differs from --currency is refused too.

Listing the definitions.

speculapro jurisdictions list

prints each code, version, name, currency, report format and kind.

Updating a definition without upgrading. SpeculaPro can publish a signed jurisdiction bundle, for example with new FATF lists or a corrected threshold. It works like a signed rule-pack update, for the whole installation:

1. Check it: speculapro jurisdictions verify <file>. It prints the code, version and signing key, and the values to confirm.
2. Import it: speculapro jurisdictions import <file>. It answers imported, or unchanged when the installation already has that version or a newer one.
3. Restart the SpeculaPro processes: running servers load an imported definition at their next start.

Each import is written to the audit log as jurisdiction.import, with the jurisdiction, the version before and after, the signing key and the file’s digest. Because a definition applies to every workspace that follows the jurisdiction, the entry belongs to the installation, not to one workspace: it doesn’t appear in a workspace’s Audit log tab. Read it from the database. An import that changes nothing (unchanged) writes no entry.

The signature is checked before the file is read, and again every time stored bundles are loaded, so an edited bundle is ignored. A bundle with the same version as an existing definition but different content is refused.

Related

• Pack contents: FATF baseline
• Pack contents: Nigeria
• Pack contents: UEMOA
• Pack contents: Sierra Leone
• Pack contents: Liberia
• Pack contents: The Gambia
• Pack contents: Guinea
• Pack contents: Kenya
• Reporting settings
• Workspace settings
• Jurisdictions API