Financial Crime World

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Gambia Struggles to Combat Money Laundering and Terrorist Financing

The Gambian government has identified fraud, drug trafficking, theft, bribery, and corruption as the main domestic money laundering (ML) threats, but its understanding of the scale and channels used to launder proceeds is limited. The country’s ability to assess organized crime, illicit goods trafficking, and arms trafficking, as well as ML vulnerabilities in legal persons, virtual assets, and other sectors, is also impaired.

Terrorism Financing Risks

The Gambian authorities have identified terrorism financing (TF) risks mainly emanating from international terrorism, but their understanding of inherent vulnerabilities could be improved significantly. The country has yet to adopt a National Counter-Terrorism Strategy that incorporates anti-money laundering and combating the financing of terrorism (AML/CFT) measures.

Systemic Vulnerabilities

In an effort to address systemic vulnerabilities, the Gambian authorities have developed strategies, including legal, institutional, and capacity gaps. However, risk assessments have identified higher-risk areas such as:

  • Banking
  • Foreign exchange
  • Remittance
  • Real estate
  • Casinos
  • Digital payment methods sectors

Mitigation Measures

The Gambian government has taken some measures to mitigate risks in certain sectors, including:

  • Supervision of the real estate sector
  • Adoption of guidelines for reporting entities, allowing simplified measures for lower-risk sectors

However, the size of the informal sector and the use of cash in transactions continue to pose ML risks.

Competent Authorities

Competent authorities are beginning to align their objectives and activities with national ML/TF risks and strategies. However:

  • Law enforcement agencies (LEAs) have focused mainly on predicate offences rather than ML
  • The Financial Intelligence Unit (FIU) has started aligning its resources to supervise high-risk sectors, but its efforts remain limited

Coordination and Cooperation

The Gambian authorities cooperate and coordinate on AML/CFT policy and operational matters to some extent. However:

  • 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
  • The country’s coordination at the operational level is evolving, but requires improvement to enhance effectiveness

National Counter-Terrorism Strategy

The Gambian government has drafted a National Counter-Terrorism Strategy (Strategy Against Terrorism (GAMSAT)), which highlights the need for improved cooperation and coordination among authorities. However:

  • There is no coordination on politically exposed persons (PEPs), non-profit organizations (NPOs), and money or value transfer services (MVTS) matters

Conclusion

The Gambian government must prioritize the development of a comprehensive AML/CFT framework to combat ML and TF risks effectively. This includes improving risk assessments, enhancing cooperation and coordination among authorities, and implementing effective measures to prevent and detect ML/TF activities.