Gambia Struggles to Combat Money Laundering and Terrorism Financing
The Gambian government has acknowledged the threats posed by money laundering (ML) and terrorism financing (TF), but its understanding of these threats is still developing.
Main Domestic Money Laundering Threats
According to a recent assessment, fraud, drug trafficking, theft/stealing or robbery, bribery, and corruption are considered the main domestic ML threats. However, the authorities’ understanding of the scale of these threats and the vulnerabilities exploited to launder proceeds is limited.
Unaddressed Threats
- Organized crime
- Illicit trafficking in stolen goods
- Arms trafficking
- ML/TF vulnerabilities of legal persons, virtual assets, tourism sector, informal economy, and extensive use of cash
- Limited understanding of TF threats attributed mainly to international terrorism
High-Risk Sectors
The Gambian government has identified high-risk areas such as:
- Banking
- Foreign exchange
- Remittance
- Real estate
- Casinos
- Digital payment methods (DPMS)
Measures to Mitigate Risks
However, measures to mitigate these risks are still in progress.
Risk Assessment and Coordination
The authorities have identified low ML/TF risks for:
- Credit unions
- Finance companies
- Village savings and credit associations (VISACAs)
But the size of the informal sector and use of cash transactions increase the risk of ML. The competent authorities are beginning to align their objectives and activities with national ML/TF risks and the National Risk Assessment Action Plan (NRA-AP).
Coordination Among Authorities
Law enforcement agencies (LEAs) have focused mainly on predicate offences rather than ML, while the Financial Intelligence Unit (FIU) has started targeting high-risk sectors such as real estate agents, foreign exchange bureaus, and banks. The authorities cooperate and coordinate on AML/CFT policy and operational matters to some extent. However, there is no coordination among authorities on politically exposed persons (PEPs) matters.
Conclusion
While the Gambian government has taken steps to address ML/TF threats, there are still significant gaps in its understanding of these threats and the measures to mitigate them. The authorities need to improve their risk assessments, supervision, and coordination to effectively combat ML and TF.