The Bank of Ghana has unveiled comprehensive Anti Money Laundering, Combating the Financing of Terrorism and Combating the Proliferation Financing of Weapons of Mass Destruction guidelines to strengthen oversight of agency banking operations across the financial sector.
The new rules, which take immediate effect, are expected to significantly tighten compliance requirements for institutions that rely on agents to deliver financial services to customers.
The guidelines are issued pursuant to section 101(2)(j) of the Payment Systems and Services Act, 2019 (Act 987) and section 52(5)(e)(i) of the Anti Money Laundering Act, 2020 (Act 1044). According to the central bank, the move is part of a broader strategy to close regulatory gaps and curb the misuse of agency banking channels for illicit financial activities.
The guidelines apply to banks, specialised deposit taking institutions, electronic money issuers, payment service providers and any other institution licensed by the Bank of Ghana to undertake agency banking activities. This broad scope reflects the growing importance of agency banking in Ghana’s financial ecosystem, particularly in driving financial inclusion and expanding access to services in underserved communities.
With agency banking networks expanding rapidly, the Bank of Ghana has acknowledged the increased risks associated with outsourcing customer facing activities to third party agents. The new framework therefore seeks to ensure that principals remain fully accountable for the actions and compliance standards of their agents.
Risk based compliance at the core
At the heart of the new guidelines is a strong emphasis on risk based AML, CFT and CPF compliance programmes. The central bank said the objective is to assist principals to develop and implement effective systems that are proportionate to the risks associated with their agency banking operations.
Principals are required to identify, assess and mitigate money laundering, terrorist financing and proliferation financing risks arising from the activities of their agents. This approach is expected to enhance the ability of financial institutions to detect suspicious transactions early and prevent abuse of the financial system.
The Bank of Ghana also stressed the importance of ensuring that agents fully understand and comply with all applicable AML, CFT and CPF laws and regulatory requirements. Institutions are expected to provide adequate training and ongoing supervision to achieve this objective.
One of the most significant aspects of the guidelines is the strengthened role of corporate governance. Under the new rules, the board and management of a principal institution are directly responsible for the enforcement and compliance of AML, CFT and CPF obligations by their agents.
The board is required to approve the risk assessment of agency banking operations prepared by management and ensure that it is properly documented. This risk assessment must be reviewed periodically within a two year cycle or earlier if there is a significant occurrence that could alter the risk profile of the institution.
By placing clear responsibility at the highest level of governance, the Bank of Ghana aims to promote a culture of compliance and accountability. The central bank believes this will discourage weak oversight and reduce the likelihood of agents being used as conduits for illicit financial flows.
Stricter Know Your Customer standards
The guidelines also reinforce strict Know Your Customer requirements across agency banking operations. Principals are required to ensure that their agents comply at all times with KYC, Customer Due Diligence and Enhanced Due Diligence policies and procedures.
This includes verifying customer identities, maintaining accurate records and applying enhanced measures where higher risk customers or transactions are identified. The Bank of Ghana has indicated that failures in KYC compliance at the agent level will be treated as failures of the principal institution.
As agency banking often involves face to face interactions at the community level, the central bank sees strong KYC controls as critical to preventing identity fraud, money laundering and terrorist financing.
While the new guidelines impose stricter obligations, industry observers believe they could ultimately strengthen confidence in agency banking and support sustainable financial inclusion. By ensuring that agents operate within a robust regulatory framework, customers may be more willing to use agency banking services for savings, payments and other transactions.
However, institutions may face higher compliance costs as they invest in training, monitoring systems and periodic risk assessments. Smaller players and fintechs in particular may need to enhance their internal controls to meet the new standards.
The issuance of the AML, CFT and CPF Agency Banking Guidelines sends a clear signal that the Bank of Ghana is intensifying its supervisory focus on emerging risks within the financial sector. As agency banking continues to play a central role in Ghana’s payments and financial services landscape, the central bank appears determined to ensure that innovation does not come at the expense of financial integrity.
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