Combating Money Laundering and Terrorism Financing: The Crucial Role of Staff
In Ghana, financial institutions play a critical role in combating money laundering and terrorism financing. According to the Anti-Money Laundering Act, 2008 (Act 749) as amended, these institutions are required to have a robust staff in place to identify and report suspicious transactions.
The Anti-Money Laundering Reporting Officer (AMLRO)
The AMLRO is responsible for developing an AML/CFT Compliance Programme and ensuring that it is implemented. This includes:
- Receiving and vetting suspicious transaction reports from staff
- Filing such reports with the Financial Intelligence Centre (FIC)
- Coordinating training of staff in AML/CFT awareness, detection methods, and reporting requirements
- Serving as a liaison officer with the Bank of Ghana (BOG) and FIC
- Being the point-of-contact for all employees on issues relating to money laundering and terrorism financing
Competence, Authority, and Independence
The AMLRO must have access to relevant information that may be of assistance in considering suspicious or unusual transaction reports. They must also have the necessary competence, authority, and independence to implement the institution’s AML/CFT compliance programme.
Cooperation with Competent Authorities
The Financial Intelligence Centre (FIC) has emphasized the importance of cooperation with competent authorities in combating money laundering and terrorism financing. Financial institutions are required to declare their commitment to comply promptly with all requests made by BOG, FIC, and other relevant competent authorities.
Scope of Unlawful Activities
Financial institutions have been reminded of the scope of unlawful activities that must be identified and reported to BOG and FIC. These include:
- Participation in organized criminal groups and racketeering
- Terrorism
- Human trafficking
- Sexual exploitation
- Illicit arms trafficking
- Others
Responding to Authorized Requests
Institutions are required to put in place procedures for responding to authorized requests for information on money laundering and terrorist financing. These procedures must enable the institution to search its records immediately, report promptly to the requesting authority, and protect the security and confidentiality of such requests.
Conclusion
The staff plays a crucial role in combating money laundering and terrorism financing in Ghanaian financial institutions. They must be equipped with the necessary skills, knowledge, and expertise to identify and report suspicious transactions effectively.