Financial Crime World

Gambia’s AML/CFT Regime Faces Challenges

The Financial Action Task Force (FATF) has expressed concerns over The Gambia’s Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) regime, citing several technical compliance shortcomings and limited understanding of money laundering and terrorist financing risks.

Limited Effectiveness of AML/CFT System

According to a recent assessment, while The Gambia has implemented an AML/CFT system, it is only effective to a limited extent. The country’s understanding of money laundering/terrorist financing (ML/TF) risks is limited, particularly with regards to the informal economy and the use of cash in transactions.

Gaps in AML/CFT Regime

The assessment identified several gaps in The Gambia’s AML/CFT regime, including:

  • Lack of criminalization of migrant smuggling
  • Designation of tax crimes as predicate offences
  • Comprehensive procedures for tracing and freezing terrorist assets
  • Transparency of beneficial ownership of legal persons and arrangements
  • Regulation and supervision of designated non-financial businesses and professions (DNFBPs)

Key ML/TF Threats

The Gambia’s authorities have identified the following key ML/TF threats:

  • Fraud
  • Drug trafficking
  • Theft/stealing or robbery
  • Bribery and corruption
  • Terrorism financing

However, their understanding of these risks is limited by a lack of assessment of organized crime, illicit trafficking in stolen goods, and the ML/TF vulnerabilities of legal persons, virtual assets, and the tourism sector.

Need for Improved Coordination

The FATF assessment also highlighted concerns over coordination among authorities on AML/CFT policy and operational matters, particularly in relation to policy initiatives and strategic guidance. The National Coordination Committee (NCC) was established in 2012 to coordinate and foster cooperation among key stakeholders, but it has yet to produce any strategic AML/CFT policy initiatives.

Recommendations

The Gambia’s authorities have been urged to address these concerns and strengthen their AML/CFT regime to prevent the misuse of its financial system for criminal activities. This includes:

  • Enhancing the effectiveness of the AML/CFT regime
  • Improving understanding of ML/TF risks
  • Addressing gaps in the AML/CFT regime
  • Strengthening coordination among authorities on AML/CFT policy and operational matters