Financial Crime World

Title: Bank of Ghana and Financial Intelligence Centre Issue Comprehensive Guideline to Combat Money Laundering and Terrorist Financing in Ghanaian Financial Institutions

Ghana’s Financial Sector Growth and Money Laundering Challenge

Ghana’s financial sector has recorded significant growth in recent decades, leading to an increasing number of cross-border transactions and financial intermediation. However, this growth has also brought about an escalating problem of money laundering (ML) and terrorist financing (TF).

In response, the Bank of Ghana (BOG) and the Financial Intelligence Centre (FIC) have issued a guide to help financial institutions design and implement effective anti-money laundering/combating the financing of terrorism (AML/CFT) compliance programs.

The Importance of the AML/CFT Guideline

This guideline, published in July 2018, is a crucial step for Ghana in maintaining a sound financial system and adhering to global regulations against ML/TF. It is issued under the Bank of Ghana & Specialized Deposit-Taking Institutions Act, 2016 (Act 930), and the Anti-Money Laundering Act, 2008 (Act 749) as amended.

Key Content Sections of the Guideline

  1. AML/CFT Directives

    • Institutional Policy
      • Compliance commitment
      • Risk management framework
      • Suspicious transaction reporting
      • Customer due diligence
      • Monitoring and respond to suspicious transactions
      • Reporting requirements
      • Record keeping
      • AML/CFT employee training program

  2. Customer Due Diligence (KYC) Procedures

    • Duty to obtain identification evidence
    • Nature and level of business relationship
    • Application of commercial judgment
    • Establishment of identity
    • Types of identity documents
    • Timing of identification requirements

Encouraging a Risk-Based Approach

Ghanaian financial institutions are encouraged to adopt a risk-based approach to identify and manage their ML/TF risks. The guideline advises accountable institutions to:

  • Document risk assessments and findings in the form of a framework
  • Consider all relevant risk factors before determining overall risk levels
  • Keep risk assessments up-to-date through periodic reviews
  • Provide periodic risk assessment information to the BOG and FIC

Role of the Anti-Money Laundering Reporting Officer (AMLRO)

Each financial institution is required to appoint an AML Reporting Officer (AMLRO), who will serve as the primary contact for all employees on issues related to ML/TF. The AMLRO’s responsibilities include:

  • Developing and implementing an AML/CFT compliance program
  • Receiving and vetting suspicious transaction reports
  • Filing suspicious and cash transaction reports with the FIC
  • Ensuring the financial institution’s compliance program is implemented
  • Coordinating staff training in AML/CFT awareness

Additional Guidelines & Information

The guideline offers additional information on cooperating with competent authorities, ML/TF risk factors, and other essential topics.

Conclusion

This guideline is essential for all financial institutions in Ghana to effectively combat money laundering and terrorist financing activities. Compliance with the requirements of the Anti-Money Laundering Act, 2008 (Act 749), Anti-Terrorism Act, 2008 (Act 762), and other relevant best practices is mandatory for all financial institutions in Ghana.