The Gambia’s Fight Against Money Laundering and Terror Financing: Assessment Reveals Key Challenges
Introduction
A comprehensive assessment of the Gambian authorities’ efforts to combat money laundering (ML) and terror financing (TF) has identified several key challenges that need to be addressed.
Main Domestic ML Threats
According to the report, fraud, drug trafficking, theft/stealing or robbery, bribery, and corruption are considered the main domestic ML threats. However, the understanding of these threats is limited, particularly in terms of assessing the relative scale of such threats and identifying vulnerabilities or channels exploited to launder proceeds.
Challenges in Combating Money Laundering
The authorities’ lack of assessment of organized crime, illicit trafficking in stolen goods, and illicit arms trafficking, as well as their limited understanding of the ML/TF vulnerabilities of legal persons, virtual assets, the tourism sector, and the informal economy, has hindered their ability to effectively combat these threats.
Terror Financing Risks
The report highlights that the authorities’ understanding of TF risks is generally evolving but more developed in certain sectors such as the State Intelligence Service (SIS), Police, DLEAG, and Financial Intelligence Unit (FIU). However, there is a need for improved appreciation of inherent vulnerabilities and determining whether or not they are being exploited.
National Counter-Terrorism Strategy
The report notes that The Gambia has yet to adopt a National Counter-Terrorism Strategy that incorporates Combating the Financing of Terrorism (CFT).
Mitigating Risks
To address these challenges, the authorities have identified higher-risk areas such as banking, foreign exchange, remittance, real estate, casinos, and digital payment service sectors. Measures have been taken to mitigate some of these risks, including supervision of the real estate sector.
Future Steps
The report highlights that competent authorities are beginning to align their objectives and activities with national ML/TF risks and the National Risk Assessment (NRA) Action Plan. However, there is still a need for improved cooperation and coordination among authorities on AML/CFT policy and operational matters.
Additionally, the report notes that private sector institutions have started to take steps to comply with anti-money laundering regulations, but there is room for improvement in terms of transparency of beneficial ownership of legal persons and arrangements.
Conclusion
The Gambian government has drafted a National Counter-Terrorism Strategy (Strategy Against Terrorism - GAMSAT), which aims to address the country’s TF risks. However, more needs to be done to ensure that all identified high-risk areas receive appropriate attention.
Overall, the report highlights the need for a comprehensive approach to combating ML and TF in The Gambia, including strengthening cooperation and coordination among authorities, improving assessment of risk, and increasing transparency of beneficial ownership.
Key Recommendations
- Strengthen cooperation and coordination among authorities on AML/CFT policy and operational matters.
- Improve assessment of ML/TF risks and identify vulnerabilities or channels exploited to launder proceeds.
- Increase transparency of beneficial ownership of legal persons and arrangements.
- Develop a comprehensive National Counter-Terrorism Strategy that incorporates Combating the Financing of Terrorism (CFT).
- Ensure that all identified high-risk areas receive appropriate attention.