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Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) & Proceeds of Crime Policy

The Bank of Ghana has issued a revised Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) & Proceeds of Crime Policy for all banks and financial institutions in Ghana. This policy aims to prevent money laundering, combat terrorism financing, and ensure compliance with relevant laws and regulations.

Sanctions for Non-Compliance

Failure to comply with the provisions contained in this Guideline shall attract appropriate administrative sanctions as prescribed in the BOG/FIC Administrative Penalties Guideline.

Revised AML/CFT&P Policy and Gap Analysis Report

As part of its compliance with the revised AML/CFT&P Policy, [Bank Name] has conducted a thorough review and revision of its internal policies and procedures to ensure that they are in line with the requirements of the Guideline. The revised policy is structured into three parts:

Part A: Obligations and Cooperation among Competent Authorities

  • Adopting a risk-based approach in supervising and monitoring banks and financial institutions
  • Monitoring and periodically assessing the level of ML/TF&PF risk of banks and financial institutions
  • Carrying out examinations of banks and financial institutions based on the Bank’s risk-assessment framework

Part B: Elements for Effective AML/CFT&P Regime

  • Developing and implementing policies indicating commitment to comply with AML/CFT&P obligations under Act 1047
  • Formulating and implementing internal rules, procedures, and controls to deter criminals from using facilities for ML/TF&PF activities

Gap Analysis Report

A gap analysis report has been prepared to identify any gaps between the existing policies and procedures of [Bank Name] and the requirements of the revised AML/CFT&P Policy. The report highlights areas where improvements are needed, including:

  • Risk assessment framework
  • Customer due diligence procedures
  • Transaction monitoring procedures
  • Reporting requirements

Conclusion

The revised AML/CFT&P policy is a crucial step towards ensuring that [Bank Name] complies with relevant laws and regulations and prevents money laundering and terrorist financing. The bank will continue to review and update its policies and procedures to ensure that they remain effective and compliant with the requirements of the Guideline.

Recommendations

Based on the gap analysis report, it is recommended that [Bank Name] takes immediate action to address the identified gaps and ensures that its policies and procedures are updated to reflect the revised AML/CFT&P Policy.