Rwanda AML Obligations for Accountants: Law 028/2023 and FIC Guidance

Rwanda's current anti-money laundering and counter-terrorist financing law dates from 2023, and accountants, auditors and tax advisers are named in it. The Financial Intelligence Centre (FIC) publishes guidance, a list of supervisors and some practical thresholds. This guide summarises what the FIC's own website and documents say, and states clearly what we could not read. If you work across the region, compare it with our guide to Kenya.

The law and the regulator

The FIC's FAQ page refers to the 2023 AML/CFT law, and its linked document is titled "Law no 028 2023 of 19 05 2023", which matches Law nº 028/2023 of 19 May 2023. The FIC's own legal basis is given on its compliance page as Law nº 002/2025 of 22 January 2025, as amended, and the FAQ page cites Law no 74/2019 and Law no 045/2021 as its establishing laws. We did not read the text of Law 028/2023 itself, only the FIC's pages and a document that reproduces parts of it.

Are accountants covered?

Yes. The FIC's FAQ lists reporting persons under Article 7 of the 2023 law, and the list includes "an auditor, accountant and tax advisor", alongside financial institutions, advocates, notaries and independent legal professionals (in specified activities), real estate agents, dealers in precious metals and stones, casinos, and trust or company service providers. The FIC's compliance page lists the Institute of Certified Professional Accountants as the supervisor of accountants and auditors, and the Rwanda Revenue Authority as supervisor of tax advisers. The same page shows 109 accountants and auditors among the counted reporting persons. Check the FIC's current list of supervisors before relying on that name.

Suspicious transaction reporting

According to the FIC FAQs, reports must cover all suspicious transactions and activities, including attempted ones, with no monetary threshold. They must be submitted "within 24 hours" using the Centre's template, electronically or through another channel the Centre sets. The FAQ says the suspicious transaction reporting requirements apply to financial institutions and designated non-financial businesses and professions.

Threshold reports

The FIC FAQ gives these amounts in Rwandan francs (FRW):

• cash transactions of FRW 10,000,000 or more for occasional customers and financial institutions;
• FRW 3,000,000 for casinos and FRW 15,000,000 for dealers in precious metals and stones;
• wire transfers of FRW 1,000,000 or more; and
• cross-border cash and bearer negotiable instrument declarations or disclosures of FRW 10,000,000 or more.

Linked transactions are counted together towards a threshold. The FAQ does not say which of these reports apply to an accountancy practice in particular, so ask the FIC or your supervisor before assuming a threshold report is or is not required.

Customer due diligence for companies and trusts

An FIC document reproducing provisions of the 2023 law (the page for it does not name the issuer) describes the duties when the customer is a legal person or legal arrangement. Under Article 13, a reporting person must understand the customer's business and its ownership and control structure; identify and verify the customer, recording its name, legal form and proof of existence, its supervisory authority and senior managers, and its registered office; and identify the beneficial owners and take reasonable steps to verify them. For trusts, it requires identifying the settlor, trustee, protector, beneficiaries or class of beneficiaries and any other natural person with ultimate effective control. Article 33 requires the registering authority to keep adequate, accurate and up-to-date beneficial ownership information and make it publicly available in a timely manner. The document does not state a percentage threshold for beneficial ownership. See our general guide to ultimate beneficial ownership.

Penalties

The FIC FAQ states the penalties as: for money laundering, 10 to 15 years' imprisonment and a fine of 3 to 5 times the value of the laundered proceeds; for terrorist financing, 20 to 25 years and a fine of 3 to 5 times the amount given, with life imprisonment where the financing results in death; and for financing the proliferation of weapons of mass destruction, 20 to 25 years and a fine of 5 to 10 times the value of the financing. We did not find penalty amounts for failures to report or to carry out due diligence.

Other FIC guidance

The FIC's "Quick Compliance Information" page lists documents on key AML/CFT obligations, a registration form for reporting persons (dated November 2023), customer due diligence measures, clients from high-risk countries and targeted financial sanctions. We could see the titles but could not open the PDFs. The FIC also issued Guideline No. 001/2025 on independent audit of AML/CFT/CFP programmes on 18 March 2025, which its web page says helps reporting persons test their compliance and helps those who audit their programmes; the page does not say who must have an audit or how often.

Practical steps

These are our suggestions, not FIC guidance. Confirm with the FIC whether your practice must register, using the registration form it publishes. Write a procedure that routes any suspicion to a named person who can report within 24 hours. Obtain and record ownership and control information for company and trust clients in line with Article 13. Keep a politically exposed persons check in your onboarding, as in our guide to politically exposed persons.

What we could not confirm

• We did not read Law nº 028/2023 or Law nº 002/2025 themselves, so article numbers beyond those stated by the FIC are not given.
• We could not open the FIC's key obligations PDF, registration form or high-risk country requirements, so we do not describe registration steps, record retention periods, compliance officer duties or tipping-off rules.
• We did not find sanctions for accountants who fail to comply, or the contents of Guideline 001/2025.
• The thresholds above come from the FIC FAQ page without article references, and we did not verify that they are current.

Frequently asked questions

Is there a minimum amount for reporting a suspicion?

No. The FIC FAQ says suspicious transaction reports have no monetary threshold and include attempted transactions.

Who supervises accountants?

The FIC compliance page lists the Institute of Certified Professional Accountants as supervisor of accountants and auditors.

Where can I find training?

See our CPD courses for accountants and finance professionals.