The registration of a bank in Cameroon constitutes a complex and highly regulated process, subject to authorization by the Ministry of Finance (MINFI) upon receipt of a favourable opinion from the Banking Commission of Central Africa (COBAC). The process necessitates the establishment of a public limited company (SA), strict compliance with minimum capital requirements, and the submission of comprehensive documentation encompassing business plans, shareholder information, and director particulars to both COBAC and the Minister of Finance.
WHAT IS THE LEGAL STATUS OF A PUBLIC LIMITED COMPANY NOT HAVING A BANKING LICENSE IN CAMEROON?
A public limited company (PLC) incorporated in Cameroon that has not yet obtained a banking licence notwithstanding any intention to engage in financial services or the adoption of a name suggestive thereof operates solely as a commercial company governed by OHADA law. Such an entity is strictly prohibited from engaging in any banking activities, including the collection of deposits, the extension of credit, or the provision of currency exchange services, until it has been duly authorized by the Ministry of Finance following a favourable opinion from the Central African Banking Commission (COBAC).
INTERMEDIARY BANK AND A BANK IN CAMEROON
A bank in Cameroon whether originating or beneficiary is a financial institution in which an account holder maintains their account, whereas an intermediary bank is a third-party institution that facilitates international wire transfers between banks that do not have a direct correspondent relationship. Intermediary banks are specifically responsible for managing currency conversion and cross-border routing, and typically operate through the SWIFT network in the discharge of these functions.
Key Differences Between a Bank & an Intermediary Bank
Primary Purpose: Banks provide retail and commercial services including loans and current accounts to their customers, whilst intermediary banks perform the specialized function of bridging gaps in international payment networks and facilitating cross-border transactions.
Customer Relationship: A customer maintains a direct relationship with their own bank, whereas they generally have no direct relationship with any intermediary bank involved in a transaction, which operates in the background without direct engagement with the account holder.
Transaction Role: Banks serve as either the originating or beneficiary point in a financial transaction representing the starting or ending destination of funds whilst the intermediary bank fulfils an intermediate role in facilitating the transfer between these two points.
Usage Frequency: Banks are used for everyday financial transactions, while intermediary banks are only brought into the process when the sending and receiving banks cannot connect directly a situation that often involves the need for foreign currency exchange.
Fees: Banks charge standard service fees for their transactions, while intermediary banks deduct their own fees directly from the transferred amount a practice that can result in the recipient receiving less than the sum originally sent.
KEY PLAYERS IN THE BANK REGISTRATION PROCESS IN CAMEROON
- Centre for the Creation of Enterprises (CFCE): Before accessing banking services, start-ups must register their businesses properly with the Cameroonian authorities. This includes obtaining a trade register number from the Commercial Court and registering with the Centre de Formalités de Création d’Entreprise (CFCE).
- Court of First Instance: In its capacity as the commercial court, it is the body responsible for establishing the company registration certificate known as the M.O Form for companies and businesses in Cameroon.
- Ministry of Finance (MINFI): The Ministry receives bank registration applications and transmits them to COBAC for technical assessment. MINFI holds the power to approve bank licenses, acting as the national regulatory authority in collaboration with COBAC.
- Banking Commission (COBAC): COBAC conducts off-site and on-site supervision of commercial banks and microfinance institutions (MFIs) to ensure safety and soundness.
- National Credit Council (NCC): Provides opinions on legal and regulatory activities, including bank classification, minimum capital requirements, and licensing (creation/closure) of banking institutions.
- Bank of Central African States (BEAC): BEAC defines and conducts monetary policy for the CEMAC region to maintain the internal and external value of the CFA franc.
- Agence Nationale d’Investigation Financiere (ANIF): Body responsible for monitoring suspicious cash flow in Cameroon.
PRELIMINARY STEPS TO CONSIDER TO REGISTER A BANK IN CAMEROON
- Choice of Corporate Structure
- The choice of corporate structure by the promoters to register a microfinance in Cameroon must be that of a Public Limited Company with a Board of Directors in conformity with Article 4 of Regulation No. 04/08/CEMAC/UMAC/COBAC of 06 October 2008.
- The choice of corporate structure by the promoters to register a microfinance in Cameroon must be that of
- Share Capital
- The share capital to be contributed by the intending shareholders of the corporate structure to engage in the bank activity in Cameroon must first be that of a public limited company which is 10,000,000 Fcfa and above in line with the OHADA Law.
- This share capital is different from the share capital required of the company to show proof it has liquidity to run the banking business in Cameroon which is 25,000,000,000 Fcfa ( Twenty Five Billion Fcfa) in conformity with Regulation R-2025/02 dated December 10, 2025, COBAC
- Choice of Management Structure
- The management structure of the corporate entity to operate the business of a bank in Cameroon must be a board of directors which must have the accredited personnel as required by Article 4 of Regulation No. 04/08/CEMAC/UMAC/COBAC of 06 October 2008
- Competence of Directors/GM/DGM: Generally, a minimum of 5 to 10 years of professional experience in banking, finance, auditing, or similar sectors is required. A post-graduate degree (typically Bac+4 or Bac+5) in Economics, Finance, Management, Law, or a related field.
- Operating Capital
- The bank company to be registered in Cameroon must show proof liquidity equivalent to 25,000,000,000 Fcfa.
- Types of Authorized Shareholders
- Individual Shareholder: A physical person who has to give a Letter of commitment addressed to the President of COBAC.
- Private Corporate Shareholder: A company registered under private law.
- Public Corporate Shareholder: A company registered under public law.
- Types of Authorized Auditors
- Individual Auditor: A physical person who is a qualified accountant, has an approval issued by CEMAC as a chartered accountant and also has a certificate of registration with the National Order of Chartered Accountants where applicable.
- Corporate Auditor: A legal person under company law registered an an accounting firm with an approval under CEMAC and a certificate of registration with the National Order of Chartered Accountants where applicable.
KEY REQUIREMENTS AND STEPS TO REGISTER A BANK IN CAMEROON
Step 1: Corporate Structure Requirement
- Form of Company: A Public Limited company with a Board of Directors
- Capital Requirement: Share capital for a Public Limited Company is minimum 10,000,000 Fcfa and the share capital required for the bank license approval is 25,000,000,000 Fcfa.
- Management Set Up Requirement: Directors, General Manager, Deputy General Manager, Auditor and Alternate Auditor. Auditors must have CEMAC approval and be registered under the National Order of Chartered Accountants whilst the executive members for management are to have between 5 to 10 years of work experience.
- Audit Set Up Requirement: An auditor and Alternate with CEMAC approval and registered in the National Order of Chartered Accountants.
- Location: A physical location plan and certificate of localization are needed.
Step 2: License Procurement Requirement/Regulatory Approval
- For the Bank Company
- A stamped application (Stamp duty: 25,000 FCFA)
- A form containing general information about the credit institution, conforming to the model defined by COBAC instruction
- A notarized copy of the credit institution's articles of association
- A notarized copy of the minutes of the constitutive general meeting
- The list of shareholders, detailing for each of them, the number of shares held, the par value of paid-up shares, the corresponding percentage of participation, and the equivalent voting rights
- Shareholder information etc.
- For the Shareholder(s)
- Individual Shareholder
- Letter of commitment addressed to the President of COBAC by the majority shareholder, conforming to the model established by current regulations
- A tax certificate issued by the tax authority of the country of taxation
- A curriculum vitae written in French, duly dated and signed
- A certified true copy of an official identity document (national identity card or passport) currently valid
- A criminal record extract less than three months old, issued by the competent authorities of the country of nationality and the country of residence etc.
- Private Corporate Shareholder
- A notarized copy of the company's articles of association
- The minutes of the entity's deliberative body authorizing the subscription to the share capital of the credit institution being established or the establishment of a subsidiary
- The list of the company's shareholders and, if applicable, their economic beneficiaries, detailing for each of them, the number of shares held, the par value of the shares, as well as the corresponding percentage of participation and the equivalent voting rights
- The annual financial statements certified by the auditors, including the balance sheets and income statements for the last three fiscal years
- The list of holdings in other credit institutions and in any other company headquartered in CEMAC or abroad etc.
- Banking Groups, Financial Holdings, Parent Entity
- The organizational chart of the group to which the applicant belongs
- The list of shareholders, and, if applicable, their economic beneficiaries, of the applicant's parent holding company and of each related company
- The certified consolidated financial statements, including the balance sheets and income statements for the last three fiscal years
- The list of holdings in the capital of “credit institutions and in any other company headquartered in the territory of a member state or” abroad, by the applicant, by its group or by the financial holding company to which it belongs
- Public Corporate Shareholder
- The act establishing the legal entity
- The act authorizing the legal entity to acquire stakes in the institution's capital
- A document by which the public legal entity, when it is the majority shareholder, undertakes to support credit development
- For the Management
- Individual Director(s) or Representative of a Corporate Director
- If applicable, the minutes of the general meeting appointing the interested party as a member of the board of directors
- A certified true copy of an official identity document (national identity card or passport) currently valid
- A curriculum vitae written in French, duly dated and signed
- A criminal record extract less than three months old, issued by the competent authorities of the country of nationality and the country of residence
- Bank Executives - General Manager & Deputy General Manager
- A stamped application (Stamp duty: 25,000 FCFA)
- A curriculum vitae written in French, duly dated and signed
- Certified true copies of diplomas
- Certified true copies of employment certificates as well as the list of previously held positions specifying the size, workforce, and nature of activities of the companies concerned
- A certified true copy of the birth certificate
- Two identity photographs
- A certified true copy of an official identity document (national identity card or passport) currently valid etc.
- Auditor(s)
- Individual Auditor
- A stamped application (Stamp duty: 25,000 FCFA)
- A copy of the minutes of the ordinary general meeting of shareholders appointing the interested party as auditor
- A certified true copy of an official identity document (national identity card or passport) currently valid
- A criminal record extract less than three months old, issued by the judicial authorities of the country of nationality and the country of residence
- Two identity photographs
- A certified true copy of the approval issued by CEMAC as a chartered accountant
- A certificate of registration with the National Order of Chartered Accountants for countries with such a body etc.
- Corporate Auditor
- A stamped application
- A copy of the minutes of the ordinary general meeting of shareholders appointing the interested party as auditor
- A form containing general information about the company, conforming to the model defined by COBAC instruction
- An extract from the Trade and Personal Property Credit Register
- A copy of the articles of association
- A certified true copy of the approval issued by CEMAC as an accounting firm
- A certificate of registration with the National Order of Chartered Accountants, for countries with such a body etc.
OTHER BANK OPERATING SECTORS IN CAMEROON
- Credit Information Bureau Services
- Credit bureaus are legal entities whose primary and exclusive activity is the collection, compilation, storage, and processing of data and information on the creditworthiness of individuals or legal entities from suppliers, with the aim of making this information available to users for a fee. They may also provide related services such as scoring, which uses statistics to assess, for example, a client's creditworthiness. They are regulated by Regulation 03/2018 CEMAC/UMAC of December 21, 2018, concerning the conditions for the operation, control, and supervision of the activities of credit information bureaus in the CEMAC region .
- Currency Exchange Services
- The exchange offices carry out purchases and sales of foreign currencies with customers in accordance with the exchange regulations in the CEMAC. They sell the currencies purchased from customers to credit institutions in Cameroon. These services are regulated by Instruction No. 11/GR/2019 .
- Payment Service Provider Services
- A third-party service that allows businesses to accept multiple forms of electronic payment in Cameroon including credit cards, debit cards, and digital wallets through a single integrated platform. Regulated by REGLEMENT-N-04-18-CEMAC-UMAC-COBAC-du-21-décembre-2018 .
- Payment Incidence Guarantee Services
- Services that relate to the use of means of payment, the handling of payment incidents and the organization of payment systems in the CEMAC. Regulated by REGLEMENT-N-03-CEMAC-UMAC-CM-du-21-décembre-2016 .
COMPLIANCE REQUIREMENTS FOR STARTUPS IN THE BANKING SECTOR OF CAMEROON
Anti-Money Laundering (AML) Obligations
All businesses operating within the jurisdiction of Cameroon are required to comply with the applicable comprehensive anti-money laundering (AML) regulations. This obligation encompasses the implementation of customer identification procedures, the maintenance of accurate transaction records, and the reporting of suspicious activities to the National Agency for Financial Investigation (ANIF).
Startup entities are required to establish written anti-money laundering (AML) policies and ensure that all employees receive adequate training on applicable compliance requirements. Failure to comply with these obligations may result in the imposition of significant penalties and the termination of banking relationships.
Know Your Customer (KYC) Procedures
Banks are required to obtain comprehensive Know Your Customer (KYC) information in respect of all business account holders. This encompasses the verification of the identity of beneficial owners, a thorough understanding of the nature of the business activities conducted, and a rigorous assessment of the associated risk profile.
In order to ensure continued compliance with applicable requirements, businesses must maintain up-to-date Know Your Customer (KYC) information and promptly notify their banking institution of any changes in ownership structure, business activities, or contact details.
Transaction Monitoring and Reporting
Banks are required to monitor all business transactions for suspicious patterns or unusual activity. Large cash transactions, frequent international transfers, or rapid account turnover may give rise to additional scrutiny and enhanced due diligence measures by the institution.
Businesses are advised to maintain comprehensive and detailed records of all transactions and to be in a position to provide satisfactory explanations for any unusual patterns to their banking partners. Transparency in the conduct of business operations is instrumental in facilitating and sustaining productive banking relationships.
Important Notes for the year 2026
Single Banking License (CEMAC): As of 2025, banks holding a valid licence in another CEMAC member state are permitted to expand their operations into Cameroon without the requirement of obtaining a separate licence, thereby facilitating the cross-border expansion of regional banking groups within the CEMAC zone.
Microfinance: Where the intention is to establish a microfinance institution rather than a full commercial bank, distinct licensing procedures apply, administered through the Microfinance Division of the Ministry of Finance.
Professional Fees: Documents often require filing through qualified legal counsel and payment of high legal and notary fees.