Financial Crime World

Gambia Fights Money Laundering and Terror Financing: Challenges Remain

Banjul, The Gambia - The Gambian authorities have identified key threats and vulnerabilities in the financial system to combat money laundering (ML) and terror financing (TF). However, a recent assessment reveals that understanding of these threats is limited, particularly in relation to predicate offences, assets confiscation, and legal persons.

Main Domestic Money Laundering Threats

  • Fraud
  • Drug trafficking
  • Theft/stealing or robbery
  • Bribery
  • Corruption

Limited Understanding of Organized Crime and Terror Financing Vulnerabilities

  • Illicit trafficking in stolen goods
  • Tourism sector vulnerabilities
  • Informal economy vulnerabilities
  • Virtual assets vulnerabilities

State Intelligence Service (SIS), Police, Drug Law Enforcement Agency (DLEAG), and Financial Intelligence Unit (FIU) Understandings

  • The authorities have a better understanding of TF threats emanating from international terrorism.
  • However, there is still room for improvement in identifying inherent vulnerabilities that could be exploited for TF purposes.

Strategies to Mitigate Systemic Vulnerabilities

  • Legal strategies
  • Institutional strategies
  • Capacity-building strategies
  • Simplified measures in low-risk sectors through the National Anti-Money Laundering and Combating Financing of Terrorism (AML/CFT) Guidelines for reporting entities

Higher-Risk Areas

  • Banking sector
  • Foreign exchange sector
  • Remittance sector
  • Real estate sector
  • Casinos sector
  • Digital payment methods (DPMS) sector

Competent Authorities’ Objectives and Activities

  • Aligning objectives and activities with national ML/TF risks and strategies.
  • Need for more effective targeting of complex and higher-risk ML activities.

National Counter-Terrorism Strategy (GAMSAT)

  • Drafted, but does not incorporate CFT yet.
  • Importance of transparency in beneficial ownership of legal persons and arrangements recognized.

Challenges and Future Directions

  • Effective combat against ML and TF requires continued effort and improvement.
  • Prioritization of complex and higher-risk ML activities is crucial with adequate resources and policy guides.