Niger, Republic of Senegal, Republic of Chad, Republic of Togo and the Federal Islamic Republic of The Comoros. 2. The Company SAMIRIS INSURANCE SA underwent prudential supervisory review by the Control Brigade of CIMA General Secretariat, from 11 to 15 May 2009. 3. The Report of this Brigade was submitted to the Regional Insurance Control Commission (CRCA) meeting in its 58th session in February 2010 in Cotonou, Benin Republic of Benin. 4. The said report maintained that the funding needs of SAMIRIS SA amounted to the sum of 1,770,000,000 (one billion seven hundred and seventy million) CFA Francs. 5. On the basis of this report of the Control Brigade, which was contested by SAMIRIS SA, the Regional Insurance Control Commission ordered the company to produce a financing plan for the above amount. 6. The Regional Insurance Control Commission (CRCA) meeting in its 60th Ordinary Session in Bamako from 26 to 30 June 2010, reviewed the share capital of SAMIRIS SA in the amount of 1,000,000,000 (one billion) CFA F as of 30 July 2010. 7. At the meeting held in Dakar in July 2011, the financing plan was finalized by the Commission in the sum of 815,000,000 (eight hundred and fifteen million) CFA Francs. 8. At the 65th session, CIMA decided to sanction SAMIRIS by placing it under constant surveillance (a sanction considered severe on the scale of CIMA). 9. At its 67th session held in Lomé on 24 April 2012, SAMIRIS SA was invited to justify its financing plan unilaterally set 815,000,000 (eight hundred and fifteen million) CFA Francs, by CRCA. 10. Not satisfied with the explanations furnished by SAMIRIS SA, the Regional Insurance Control Commission rejected the plan and decided to suspend the leaders of the Company and to appoint a Provisional Administrator. 11. The CEO Mr. Roger Kamdem was suspended from duty and a legal liquidator appointed by CIMA. C. COMPLAINTS The Applicant prays the Court to: - DECLARE illegal Articles 6, 22, 48 et seq. of the Treaty of 10 July 1992 establishing CIMA. - DECLARE illegal Articles 316, 317, 325-1 et seq. of the Insurance Code of CIMA member countries. - RULE that the member states of the Inter-African Conference on Insurance Markets deliberately violated international human rights protection conventions of which they are signatories;

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