The Ghana Association of Banks has rejected claims suggesting that Ghana’s banking sector has suffered a systemic failure in safeguarding financial integrity.
The association was responding to commentary that linked alleged criminal activity in the so called Abu Trica case to weaknesses within regulated banks.
In a formal statement, GAB stated clearly that no bank operating in Ghana has been cited, sanctioned, or found culpable by any regulatory or law enforcement authority in connection with the matter. According to the association, allegations circulating in the public domain have not been backed by official findings from competent institutions.
GAB explained that there has been no published determination by the Bank of Ghana, the Financial Intelligence Centre, the Economic and Organised Crime Office, or any foreign authority establishing that failures within Ghana’s regulated banking institutions facilitated the alleged criminal conduct.
“To imply systemic failure without such evidence risks conflating allegations with facts, and investigation with adjudication,” the association said. It stressed that investigations alone do not amount to proof of wrongdoing and that conclusions should only follow formal adjudication by mandated institutions.
Ghana’s Strong Regulatory Framework
The association further underscored that Ghana’s banking sector operates under what it described as “a robust and evolving regulatory and supervisory framework.” According to GAB, banks are bound by stringent obligations under the Anti Money Laundering Act 2020, including updated AML guidelines issued in 2025, the Anti Terrorism Amendment Act 2014, the Banks and Specialised Deposit Taking Institutions Act 2016, and the Payment Systems and Services Act 2019.
“These obligations include customer due diligence, enhanced due diligence for higher risk relationships, transaction monitoring, and the mandatory filing of Suspicious Transaction Reports (STRs).”
GAB
GAB added that compliance with these requirements is supported by detailed directives and ongoing supervision by the Bank of Ghana.
Banks Are Not Investigators
A key clarification offered by GAB focused on the distinct role of banks within the anti money laundering framework.
“Importantly, the evaluation and investigation of reported suspicious transactions are undertaken by the FIC and relevant law enforcement agencies, rather than by banks; whose role is limited to monitoring, reporting under the law and cooperating with law enforcement agencies in their investigative processes.”
GAB
GAB explained that banks are required to report suspicions, not conclusions, and that such reports are confidential by law. It noted that the effectiveness of the AML system depends heavily on intelligence gathering, inter agency collaboration, and investigative follow through, much of which necessarily occurs outside public view.
Illicit Funds Do Not Automatically Mean Failure
The association also addressed what it described as a common misconception in public commentary. GAB stated that the presence of illicit funds within the banking system does not, by itself, indicate regulatory or institutional failure.
“Sophisticated financial crimes, particularly cyber enabled scams, are deliberately structured to evade detection, often exploiting social engineering, cross border channels, non bank platforms, cryptocurrency wallets, decentralised finance platforms, gift cards and digital vouchers, peer to peer digital applications, direct acquisition of movable and immovable assets, and other digital payment rails that extend well beyond traditional banking controls.”
GAB
GAB explained that these initial stages of criminal activity often take place entirely outside the visibility and control of banks and regulators. By the time illicit funds enter the formal banking system, they may appear legitimate.
“At this stage, banks are not receiving ‘dirty money’ in an obvious sense, but funds that may have already passed through multiple non bank channels designed specifically to obscure criminal origins,” the statement said. GAB noted that such funds often present as proceeds from asset sales, consultancy services, remittances, or business transactions supported by documentation that appears verifiable under existing know your customer and due diligence procedures.
Delayed Detection Is Not Weak Compliance
The association also responded to suggestions that delayed detection or reporting is evidence of weak compliance. GAB said this interpretation misunderstands how AML frameworks are designed to function.
“Banks are required to report suspicions, not conclusions, and such reports are confidential by law,” the association reiterated. It added that “the absence of public enforcement announcements should not be misconstrued as regulatory inaction or institutional complacency.”
GAB further cautioned against drawing direct parallels between enforcement outcomes in Ghana and those in Europe or North America. According to the association, differences in legal systems, supervisory traditions, and disclosure regimes mean that enforcement actions are not always directly comparable across jurisdictions.
While defending the sector, GAB acknowledged that continuous improvement remains necessary. The association stated that banks are already investing significantly in transaction monitoring systems, staff training, risk based supervision, and collaborative engagement with regulators.
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