Management of Inactive Accounts and Dormant Assets in the CEMAC Region

Fonyam and Partners Law Firm – Douala

The Central African Economic and Monetary Community (CEMAC) has issued new regulations that address how financial institutions handle inactive accounts and dormant assets. These changes come into effect on September 1, 2025, through Regulation No. 02/25 of July 12, 2025. This regulation creates a legal framework for managing these financial resources and introduces the possibility of establishing a Caisse de Dépôt et Consignation (CDC) in each member state.

Legal Foundation

The regulation is designed to:

• Clearly define what qualifies as an inactive account or dormant asset.
• Outline the responsibilities of financial institutions in handling these accounts.
• Detail the procedures for transferring unclaimed funds to a designated authority.

Understanding Dormant Assets and Inactive Accounts

Dormant Assets
These include cash, securities, or other financial items held by a bank for someone who has not interacted with the account for 10 years.

Inactive Accounts
An account is considered inactive if:

• There have been no transactions for 12 months (for current or payment accounts) or 36 months (for savings accounts).
• The account holder hasn’t used any other accounts within the same institution.
• The inactivity isn’t caused by the bank’s own actions.

Inactive Safe Deposit Boxes
A safe deposit box is considered inactive if:

• It hasn’t been accessed for 36 months.
• The account holder has no other interactions with the bank.
• Rental fees remain unpaid during this time.

Bank Responsibilities Under the New Law

Notification Requirements
Banks must notify account holders, their beneficiaries, or authorized representatives about the inactivity of their accounts or safe deposit boxes.

Efforts to Locate Owners
Financial institutions must attempt to find the owner for:

• 9 years for current or payment accounts.
• 7 years for savings accounts and safe deposit boxes.

Declaring Assets as Unclaimed
If no contact is made after 10 years, the assets are labeled “unclaimed” and must be handed over to:

• The Caisse de Dépôt et Consignation (CDC), if it exists in the country.
• The National Directorate of the BEAC (Central Bank), if there is no CDC.

Handling of Inactive Safe Deposit Boxes
Banks are required to:

• Open the safe deposit box in the presence of a bailiff.
• Make an inventory of the contents.
• Transfer any valuables or securities to the CDC or BEAC.

Annual Reporting Obligation
By March 31 each year, banks must submit a report to:

• COBAC (Banking Commission of Central Africa),
• and the CDC or National Directorate of the BEAC.

This report must include the number of inactive accounts, safe deposit boxes, and the steps taken to reach the owners.

Final Thoughts

This new regulation brings structure and transparency to how dormant and inactive financial assets are handled in the CEMAC region. It ensures that unclaimed funds are managed responsibly. Financial institutions must strictly follow the notification, search, and reporting processes to stay compliant and avoid penalties.

If you need legal assistance to understand or comply with this regulation, Fonyam and Partners Law Firm is here to help.

Contact us for expert legal advice.
Douala, Cameroon
‪+237 675 869 695‬
www.Banyongfonyamjoniejr.com

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