Title: Gambia’s AML/CFT Regime Under Scrutiny: Key Challenges Highlighted in a New GIABA Report
Overview: Evaluating The Gambia’s Anti-Money Laundering and Counter-Terrorist Financing Measures
The Inter-Governmental Action Group against Money Laundering in West Africa (GIABA) has recently released a report on The Gambia’s anti-money laundering (AML) and counter-terrorist financing (CTF) measures [1]. The document outlines significant advancements in The Gambia’s legal and institutional framework while acknowledging areas for improvement.
About GIABA: Reinforcing Financial Systems in West Africa
GIABA is an ECOWAS-specialized institution tasked with fortifying the financial systems of its member states against money laundering, terrorist financing, and weapons of mass destruction proliferation [2]. GIABA’s FATF-style recommendations serve as the global benchmark for AML and CTF [3].
Progress and Challenges in The Gambia’s AML/CFT Regime
After evaluating The Gambia’s regime, GIABA identified multiple strengths but also mentioned various gaps that need improvement [4]. Findings include:
Progress since 2008
- The government strengthened its legal framework
- Enhanced institutional capability
- Improved investigation and prosecution
Key Challenges
Insufficient Risk Awareness and Understanding
- National Risk Assessment incomplete
- Lack of comprehensive policy and monitoring mechanism
Inadequate use of Financial Intelligence
- Limited resources and knowledge gaps
- Limited STR filings by DNFPBs and NBFIs
Inadequate International Cooperation
- Lack of a designated authority for UNSCR 1267 Committee proposals
Recommendations: GIABA’s Path Forward for The Gambia
GIABA has proposed several measures to help The Gambia address its challenges, including enhancing international cooperation [9], strengthening preventive measures, and improving the transparency and monitoring of legal entities and arrangements [10].
Conclusion
The GIABA report offers valuable insights into The Gambia’s current state of AML/CFT measures and outlines necessary improvements. The full report is available on the GIABA website [11].
[1] GIABA (2022), Anti-money laundering and counter-terrorist financing measures – The Gambia, Second Round Mutual Evaluation Report, GIABA, Dakar. [2] For more information about GIABA, visit: www.giaba.org. [3] GIABA (2022), Anti-money laundering and counter-terrorist financing measures – The Gambia, Second Round Mutual Evaluation Report, GIABA, Dakar, page 5. [4] Idem, executive summary, p. 8-10. [5] Idem, chapter 1, ML/TF risks and context, p. 22. [6] Idem, chapter 2, national AML/CFT policies and coordination, p. 44-45. [7] Idem, chapter 3, legal system and operational issues, chapter 3.2, p. 60-62. [8] Idem, chapter 8, international cooperation, p. 187, 189. [9] Idem, recommendation 36, p. 248. [10] Idem, recommendations 24 and 25, p. 225-226. [11] GIABA (2022), Anti-money laundering and counter-terrorist financing measures – The Gambia, Second Round Mutual Evaluation Report, GIABA, Dakar.