Financial Crime World

Gambia Under Scrutiny for Risk-Based Approach to Anti-Money Laundering

The Financial Action Task Force (FATF) and the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA) have recently assessed The Gambia’s progress in strengthening its legal and institutional framework to combat money laundering and terrorist financing. While significant strides have been made, there are still unmet challenges that need to be addressed.

National Risk Assessment

The Gambia completed its first National Risk Assessment (NRA) in 2020, but the scope and comprehensiveness of the assessment can be expanded. The report highlights gaps in understanding and addressing money laundering and terrorist financing (ML/TF) risks. The Gambian authorities have made efforts to improve their understanding of domestic ML/TF risks, but a policy based on assessment findings is lacking.

Coordination and Cooperation

The National Coordination Committee provides strong coordination between law enforcement authorities and other relevant bodies, but operational initiatives by law enforcement agencies have yet to yield significant outcomes in addressing high-risk areas. The report also notes that financial intelligence units (FIUs) in The Gambia have limited use of financial intelligence to support investigative activities.

Proliferation Financing

The Gambia lacks a coordination mechanism or demonstrated efforts to address proliferation financing, an area of concern. Furthermore, the report highlights challenges in implementing confiscation measures due to identifying and tracing criminal assets, implementing United Nations Security Council Resolution (UNSCR) 1267 and related UNSCR 1373 measures, and lack of clear procedures for implementing these resolutions.

Shortcomings in Anti-Money Laundering/Counter-Terrorist Financing Regime

The report identifies various shortcomings in The Gambia’s anti-money laundering/counter-terrorist financing regime, including:

  • Risk assessments and risk-based approach
  • Legal and institutional framework
  • Financial intelligence units and other relevant authorities
  • Supervision and enforcement
  • Transparency and beneficial ownership
  • Mutual legal assistance, extradition, and international cooperation

Addressing Shortcomings

To strengthen its anti-money laundering/counter-terrorist financing system and effectively mitigate money laundering and terrorist financing risks, The Gambia must address these shortcomings. Implementing a comprehensive approach that includes policy development, coordination, and cooperation is crucial for the country’s progress in this area.