Ghana’s anti money laundering regime  under evaluation
• Elsie Addo Awadzi — 2nd Deputy Governor, Bank of Ghana

Ghana’s anti money laundering regime under evaluation

AHEAD of the third round mutual evaluation of Ghana’s anti money laundering regime by the Financial Action Task force (FATF) in 2025, the Financial Intelligence Centre (FIC) in partnership with the Bank of Ghana (BoG) has commenced a risk assessment of the country’s present status.

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The NRA is aimed at identifying, assessing and demonstrating the country’s understanding of its Anti-money Laundering, Terrorist Financing and Proliferation Financing (AML/CFT/PF) risks, and put in place adequate measures to mitigate the identified risks.

It will be undertaken by stakeholders in line with the relevant provisions of the Anti-Money laundering Act, 2020 (Act 1044). Stock of the types and level of ML/TF/PF risks the country currently faces will be undertaken, using the World Bank’s assessment tools.

It will also help identify the sources of these risks (including domestic, sub-regional, regional and globally), and the preventive measures including resource allocation to mitigate all identified risks speedily.

It will be recalled that the country’s last mutual evaluation carried out in 2016 identified significant deficiencies in the AML/CFT/PF regime, leading to a grey-listing by FATF in 2018 until 2020 when Ghana was de-listed following extensive reforms to strengthen the regime, in line with FATF recommendations.

The grey-listing of Ghana by FATF also led automatically to Ghana’s black-listing by the European Union authorities, and then by the United Kingdom authorities.

These adverse listings meant that existing and potential correspondent banks in the EU and beyond, foreign investors and counterparts restricted their business dealings with Ghanaian banks and entities, given the enhanced due diligence requirements (with attendant costs and compliance risks) they were required to comply with before dealing with Ghanaian entities.

The costs of these listings were therefore significant from a reputational and economic standpoint, and it was therefore a major source of relief that due to the coordinated and effective reforms undertaken at policy, legislative, regulatory and administrative levels, Ghana was restored to good-standing status with the FATF, the EU and the UK.

Sustaining gains 

At the opening of the NRA in Accra, the Second Deputy Governor of the Bank of Ghana, Elsie Addo Awadzi, said as the country proceeded to the third round of the mutual evaluation process next year, it was imperative that it sustained the fruits of the hard work exerted by all stakeholders that led to critical reforms and implementation that persuaded FATF, the EU and the UK to remove Ghana from any adverse listings for ML/CFT/PF risks.

She said all stakeholders must therefore continue to work to maintain an effective AML/CFT/PF regime that stands the test of time.

“This NRA presents us a rare opportunity to critically self-assess, taking into account the evolution of our financial system and all key sectors of our economy and how business is being conducted since the last assessment,” she stated.

Making changes 

The CEO of the FIC, Kwaku Dua, for his part, said the NRA would help evaluate changes in the AML/CFT/PF risk profile and put in place appropriate mitigating measures to address same.

He said the results would inform the country’s policy makers on areas to tighten within the current regime and properly channel resources to mitigate the risks identified.

Mr Dua noted that Ghana would be the first to be subjected to the next round of mutual evaluations hence the need to start preparing early.

“You would recall that we were also the first to be evaluated in the second round. As I have just indicated, the demonstration of understanding of a country’s risk profile conduct is the first step towards preparing for a mutual evaluation exercise, hence the NRA.”

“Once again, we are being asked to roll up our sleeves and get to work again. I have no doubt in my mind that with your support we can do it again. We will do it again to maintain the good image of Ghana in the sub- region as far as AML/CFT is concerned,” he stated.

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