Checklist: serving an African private clientele in compliance with the asset-recovery framework
- Identify the links of the client and his entourage with the exercise of public functions, public contracts, concessions and state-owned enterprises.
- Clarify the origin of the wealth in a documented manner, distinguishing income from legitimate activities, inheritances and income linked to political power.
- Assess the degree of corruption in the country and the likelihood of a change of regime that could trigger a freeze.
- Apply the enhanced due-diligence measures provided for politically exposed persons and document acceptance decisions.
- Plan the course of action in the event of a freeze, a request for mutual assistance or a suspicious-activity report, including the retention of documents.
- Avoid any participation in structures designed to conceal the identity of the beneficial owners or the origin of the funds.
- Follow developments in the freezes ordered by the Federal Council and in the proceedings concerning the client’s country.
For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.