The showdown between the Caisse des Dépôts et Consignations du Cameroun (Cdec) and banking institutions reveals a major legal tension: the ambiguous coexistence of national law and CEMAC community standards. Beyond the numbers, this dispute raises questions about financial governance and the stability of the regional banking system. Analysis…
On May 29, 2024 in Yaoundé, Richard Evina Obam, Director General of Cdec, and Pierre Emmanuel Nkoa Ayissi, National Director of Beac, signed a minutes of meeting formalizing the transfer of the sum of 3.9 billion CFA francs from Beac to an account opened by Cdec in its books. The transferred funds, stemming from judicial deposits previously held by Beac, fall within the framework of the provisions of the law of April 14, 2008 governing deposits and consignments in Cameroon.
Indeed, in accordance with this law, a decree from the Prime Minister dated December 1, 2023 sets a six-month deadline for public and private entities, until May 31, 2024, to voluntarily transfer funds and assets devolved to Cdec. It is in execution of this decree that the national Beac decided to transfer the funds to Cdec.
It is also in compliance with this decree that several financial institutions have transferred funds to Cdec. Allianz Assurances Cameroon led the way in life insurance, with over 1.5 billion CFA francs of dormant contracts transferred to Cdec. In the same vein, a pilot agreement was signed on November 2, 2023 between Banque Atlantique Cameroon and Cdec. SCB Cameroon followed with a transfer minutes signed in June 2024. At one point, Société Générale was mentioned among the actors involved. The French bank later reconsidered following an order from the Central African Banking Commission that abruptly halted the flow of fund transfer agreements between Cdec and its counterparts.
In a letter addressed to the general managers of credit, microfinance, and payment institutions on July 11, 2025, the Secretary General of Cobac instructed them to suspend the process of transferring dormant assets to Cdec. Marcel Ondele notes that the transfer requires prior clarification of the nature of these assets as well as the definition of the modalities for their conservation, management, and even restitution. To date, he states in his correspondence, “there is no regulatory framework governing the aforementioned points in the Economic and Monetary Community of Central Africa (Cemac), except for rules relating to the accounting treatment of these assets.”
Judicial escalation and institutional reactions
In the same vein, Cobac indicates that it has initiated work aimed at regulating, at the community level, the treatment by credit, microfinance, and payment institutions of dormant assets and their transfer to authorized institutions. In the background, Cobac emphasizes the need to preserve sub-regional financial stability as well as the need to control operational risks related to the conservation and management of assets. The financial sector watchdog also points out the risks of disputes between national institutions, financial institutions, and holders of these assets or their heirs.
Ignoring this constructive approach of the community regulator, Cdec maintains pressure through several complaints filed in national courts for misappropriation of public funds against the leaders of credit institutions. On another front, it initiates seizures (accompanied by third-party notices) amounting to several billion CFA francs against these institutions and sends threats to the international parent companies of the banks.
The highlight of the show, in early October 2025, sees Cdec dragging seven bank CEOs before the Mfoundi High Court. The complaints concern the leaders of SCB Cameroon, Citibank, SG Cameroon, Ecobank, Afriland First Bank, Citibank Cameroon, and CBC. Among other alleged grievances: coercion, refusal to transfer assets devolved to CDEC, and even usurpation of function.
In response to this new legal saga, the President of the Professional Association of Credit Institutions of Cameroon (Apeccam), Gwendoline Abunaw, who is also the Managing Director of Ecobank, writes to Cobac on October 6, 2025 to draw attention to the high risk of a crisis in the Cameroonian banking system due to the actions taken by Cdec.
On its part, Cobac is working to regulate the recovery of dormant assets in the community. On October 22, 2025, it sends a letter to the Minister of Finance, Louis Paul Motaze. The sub-regional institution, which had already in May 2025 requested banks in the area to communicate the exact volume of the funds concerned, reminds the Minister that two major regulations came into force on September 1, 2025 throughout the CEMAC zone: Regulation No. 01/25 on the conditions of operation of Deposit Institutions, and Regulation No. 02/25 concerning the treatment of inactive accounts and dormant assets.
Cobac regulates…
These community texts, directly applicable in all member states according to Article 41 of the CEMAC Treaty, establish a precise legal framework. According to these texts, banking institutions holding inactive accounts for at least ten years must transfer the assets to the Deposits and Consignments Fund of their country of establishment. This sentence suggests that Cobac supports CDEC and that there is no problem, but further verification is needed!
In the letter, Cobac expresses surprise at the judicial actions initiated by Cdec when a sub-regional legal framework is now in force.
…but Cdec stands its ground
Established by Law No. 2008/003 and organized by Decree No. 2011-105, Cdec operates strictly on a national basis, without alignment with CEMAC treaties. Problem: Cdec is a specialized financial institution (COBAC Regulation R-2009/02), but it is not subject to community regulation. Decree No. 2011-105 of April 15, 2011 on the organization and functioning of the Caisse des Dépôts et Consignations assigns this institution the legal status of a public institution of a particular type in accordance with Law No. 2008/003 of April 14, 2008 governing deposits and consignments. However, this decree is not aligned with any applicable international treaty. From a legal point of view, international treaties and standards take precedence over national laws, in accordance with the principle of hierarchy of norms. Cdec must, from this point of view, align itself with the two regulations that came into force on September 1, 2025 and are now community law regarding the management of dormant assets.
In an open letter to the President of the Republic in April 2025, financial expert Babissakana already pointed out the ambiguity of the normative framework of Cdec, noting in particular that “the mission of Cdec (article 4) to ‘receive, keep, and manage public or private sums and assets, in accordance with the laws and regulations in force’ clearly falls within the banking or financial intermediation profession governed by the Treaty of March 16, 1994 establishing the Economic and Monetary Community of Central Africa (CEMAC), in particular, the convention governing UMAC. Due to its activities, the convention of January 17, 1992 on harmonization of banking regulations in the States of Central Africa applies, and COBAC is the regulator.”
To put an end to this legal ambiguity, Cobac has put into effect the two aforementioned regulations on September 1st. CEMAC Regulation No. 02/25 imposes obligations on institutions subject to Cobac in terms of monitoring inactive accounts, searching for and informing their holders, and transferring dormant assets to the Deposits and Consignments Fund (or the National Directorate of Beac) at the end of a ten-year period of inactivity.
However, considering the pre-existence of national legislation in the field and the importance of not weakening the financial forecasts of active Deposits and Consignments Funds, Article 26 of this regulation provides that “institutions subject to this regulation that have already recorded at least ten years of inactivity on accounts and safes housed in their books at the date of entry into force of this regulation, transfer the assets held in these accounts to the Deposits and Consignments Fund of the country of their establishment (…).”
As we mentioned earlier, in preparation for the implementation of this provision, the General Secretariat of Cobac, through a circular letter dated May 21, 2025, requested credit institutions in CEMAC to transmit, according to the format provided, the volume of dormant assets that should be transferred to the Deposits and Consignments Fund or the National Directorate of Beac of jurisdiction.
Starting from July 2025, the General Secretariat of Cobac has imposed penalties on institutions that have not complied with this request. The analysis of information continues, and efforts to support the institutions subject to the transfer of these funds are being finalized. None of this seems to have deterred Cdec. On the contrary, its determination to accelerate recoveries is fueled.
Moreover, this conflict goes beyond a simple institutional dispute: it questions the hierarchy of legal norms in an integrated economic space and jeopardizes the stability of the Cameroonian and sub-regional banking system. The coexistence of divergent national law and CEMAC community regulations cannot be resolved through isolated legal actions. Given the considerable stakes involved, touching on the financial stability of the leading sub-regional economy, we should not witness a shadow play unfolding over such a long period. Only institutional mediation, driven by assertive political leadership, will harmonize practices, restore confidence, and ensure the necessary normative coherence for financial security and economic integration in the sub-region.
