OFNAC Publishes Provisional Lists of Senegalese Asset Owners and Defaulters

• OFNAC has received an 'important volume' of declarations of patrimoine from individuals subject to the law.
• Provisional lists of declared and undeclared assets will be published by August 10, 2026.
• Lawyers should advise clients on potential compliance exposures arising from the publication of these lists.

The declarations are currently being registered and checked for compliance with Article 6 of Law No. 2025-13, which requires OFNAC to verify each declaration before taking any action.

The Office National de Lutte contre la Corruption (OFNAC) has made significant progress in receiving declarations of patrimoine from individuals subject to the law. According to a statement released on August 3, OFNAC received an 'important volume' of declarations during the last days leading up to the July 31 deadline. This mobilization is seen as a positive development by OFNAC, which is responsible for verifying each declaration before making any decisions regarding the individual's status.

The declarations are currently being registered and checked for compliance with Article 6 of Law No. 2025-13, which requires OFNAC to verify each declaration before taking any action.

Law No. 2025-13, enacted on September 3, 2025, introduced the obligation for individuals with assets in Senegal to declare their patrimoine. Article 5 of this law and Article 15 of its implementing decree (No. 2025-1835) specify that OFNAC must verify each declaration before publishing any information about the individual's status. The law also requires OFNAC to publish provisional lists of individuals who have declared their assets and those who have failed to do so.

The publication schedule for these lists is as follows: provisional lists will be published by August 10, 2026, with a definitive list following later after the completion of verification and authentication processes.

The upcoming publication of provisional lists may reveal undisclosed assets belonging to clients or their associates, potentially exposing them to compliance risks. Lawyers should be aware of this development and advise their clients accordingly. The increased transparency brought about by the law is a significant step towards asset ownership in Senegal, but it also presents challenges for individuals who have not complied with the new regulations.

Lawyers should watch for the upcoming publication of provisional lists, which may reveal clients' or their associates' undisclosed assets, and advise them on potential compliance exposures.

Source: Original reporting via SenePlus