The Fight Against Money Laundering Through Shell Companies in Cameroon: A Legal Appraisal

Abstract

Money laundering through shell companies is a major risk to the integrity of financial systems globally, and Cameroon is exposed to this threat through its economic structure, banking system, and regional position within the Central African Economic and Monetary Community (CEMAC). This article undertakes a legal appraisal of the fight against money laundering through shell companies in Cameroon. The study examines the conceptual and legal nature of shell companies, distinguishing them from related concepts such as shelf companies, nominee companies, and trusts, and analyses the mechanics of money laundering and the role of shell companies in each stage, particularly in layering and integration. The article then systematically examines the Cameroonian legal and institutional framework on anti‑money laundering, including CEMAC Regulation 01/CEMAC/UMAC/CM of 16 April 2016 on the prevention and suppression of money laundering and of the financing of terrorism in Central Africa, domestic criminal and financial legislation, and OHADA corporate law, including the Revised Uniform Act of 30 January 2014 on Commercial Companies and Economic Interest Groups. The study identifies significant gaps in the current framework, particularly the absence of explicit regulation of shell companies, limited beneficial ownership transparency, weak enforcement capacity, and inadequate institutional coordination between ANIF, COBAC, and law enforcement agencies. The article further analyses the use of shell companies in money laundering in Cameroon, identifying typologies such as false transactions, layering through multiple corporate structures, asset holding and integration, and loan issuance and financial intermediation. The study notes that these typologies are observed in sectors such as real estate, import–export, public procurement, and banking, and underscores the scarcity of documented case law and official typologies in Cameroon. The findings reveal that while Cameroon has established a foundational anti‑money laundering regime, it does not explicitly target shell companies, and significant reforms are needed to strengthen beneficial ownership disclosure, supervision of company formation actors, and enforcement mechanisms. The article proposes legislative reforms to require comprehensive beneficial ownership disclosure and to establish a central registry of beneficial owners, institutional reforms to strengthen the capacity of ANIF, COBAC, and law enforcement agencies, and policy reforms to enhance the supervision of designated non‑financial businesses and professions and align Cameroonian anti‑money laundering practices with international standards, particularly the FATF Recommendations. This study contributes to Cameroonian anti‑money laundering scholarship by foregrounding the specific issue of shell companies as vehicles for money laundering. While existing literature addresses money laundering in Cameroon more broadly, few works focus explicitly on the legal regime governing shell companies and their misuse for illicit financial flows. The findings of this study underscore the need for a comprehensive legal response that addresses incorporation, disclosure, and supervision of corporate vehicles, and that strengthens beneficial ownership transparency and enforcement capacity to reduce the misuse of shell companies for money laundering.