Financial Crime World

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Framework for Guiding Staff in Combating Money Laundering and Financing of Terrorism

In a bid to ensure effective compliance with anti-money laundering (AML) and combating the financing of terrorism (CFT) regulations, financial institutions are required to have a robust framework in place. This framework serves as a guide for staff on the measures to be taken to prevent, detect, and report suspicious transactions.

Risk Assessment and Reporting

Accountable institutions are mandated to conduct regular risk assessments to identify potential AML/CFT risks. These assessments must consider all relevant risk factors and provide a comprehensive overview of the institution’s overall risk level and mitigation strategies. The findings of these assessments should be documented in a framework that is reviewed periodically and updated as necessary.

Additionally, accountable institutions are required to report their risk assessment results, ML/TF risk profile, and effectiveness of risk control measures to their respective Boards of Directors on a regular basis. The frequency of reporting shall be determined by the Board.

Appointment of Anti-Money Laundering Reporting Officer

Each financial institution is required to appoint an Anti-Money Launderling Reporting Officer (AMLRO) who will be responsible for implementing the institution’s AML/CFT compliance program. The AMLRO shall report operationally to the Board and have access to relevant information that may assist in considering suspicious or unusual transactions.

Duties of AML Reporting Officer

The AMLRO shall perform the following duties:

  • Develop an AML/CFT Compliance Programme
  • Receive and vet suspicious transaction reports from staff
  • File suspicious and cash transaction reports with the Financial Intelligence Centre (FIC)
  • Ensure that the institution’s compliance programme is implemented
  • Coordinate training of staff in AML/CFT awareness, detection methods, and reporting requirements
  • Serve as a liaison officer with the Bank of Ghana (BOG) and FIC and point-of-contact for employees on issues relating to money laundering and financing terrorism

Cooperation with Competent Authorities

Financial institutions are required to declare their commitment to comply promptly with all requests made by competent authorities, including the BOG and FIC. The institution’s procedures for responding to authorized requests for information shall meet specific requirements, ensuring that the security and confidentiality of such requests are protected.

Scope of Unlawful Activities

Accountable institutions shall identify and report proceeds of crime derived from unlawful activities, including but not limited to:

  • Participation in organized criminal groups and racketeering
  • Terrorism, including terrorist financing
  • Trafficking in human beings and migrant smuggling
  • Sexual exploitation, including sexual exploitation of children
  • Illicit trafficking in narcotic drugs and psychotropic substances
  • Illicit arms trafficking
  • Illicit trafficking in stolen and other goods
  • Corruption and bribery
  • Fraud
  • Counterfeiting currency
  • Counterfeiting and piracy of products
  • Environmental crime
  • Murder, grievous bodily injury
  • Kidnapping, illegal restraint, and hostage-taking
  • Robbery or theft
  • Smuggling
  • Tax evasion
  • Extortion
  • Forgery
  • Piracy
  • Insider trading and market manipulation

These unlawful activities are subject to predicate offenses under the Anti-Money Laundering Act, 2008 (Act 749) as amended and Anti-Terrorism Act, 2008 (Act 762) as amended.

By implementing this framework, financial institutions can ensure effective compliance with AML/CFT regulations, protect their reputation, and maintain public trust.