The Bank of Ghana has stepped up regulatory oversight of the foreign exchange market with the issuance of the Anti Money Laundering and Combating of Terrorism Financing Guidelines for Forex Bureaus 2025.
The new directive places forex bureaus under closer supervision, requiring them to report all sales and purchases of foreign currencies that meet or exceed a threshold of GH¢20,000 or its foreign currency equivalent to the Financial Intelligence Centre. The central bank says the move is aimed at strengthening Ghana’s defences against money laundering, terrorism financing and the proliferation financing of weapons of mass destruction.
According to the Bank of Ghana, the reporting obligation applies to all forex bureaus without exception and covers both cash and non cash transactions. Any amount that meets the threshold or any other level that may be determined by the Financial Intelligence Centre must be promptly reported in line with established procedures.
Mandatory Reporting and Confidentiality Rules
A key feature of the new guidelines is the strict confidentiality requirement imposed on forex bureaus. Directors, management and employees are expressly prohibited from disclosing to customers or third parties that a report has been filed with the Financial Intelligence Centre. The Bank of Ghana views this non disclosure rule as critical to preserving the integrity of intelligence gathering and preventing potential offenders from evading regulatory scrutiny.
By reinforcing confidentiality obligations, the central bank seeks to align forex bureau operations with global best practices in financial intelligence reporting. Any breach of this requirement could expose institutions and individuals to regulatory sanctions and other enforcement actions.
The guidelines also place significant emphasis on customer screening and due diligence. Forex bureaus are required to screen all customers prior to conducting transactions, ensuring that they are not dealing with individuals or entities that are sanctioned either internationally or domestically. These sanctions lists include those issued by the United Nations Security Council, the United States Office of Foreign Assets Control, the European Union, His Majesty’s Treasury, the African Union and ECOWAS, as well as any competent authority or supervisory body.
The Bank of Ghana has made it clear that forex bureaus must not transact business with sanctioned customers under any circumstances. This requirement is intended to prevent Ghana’s foreign exchange market from being used as a conduit for illicit financial flows linked to criminal or terrorist activities.
Risk Based Approach to AML Compliance
Beyond reporting and customer screening, the central bank is requiring forex bureaus to adopt a risk based approach to identifying and managing money laundering, terrorism financing and proliferation financing risks. This approach compels institutions to assess the level of risk associated with their customers, products, services and delivery channels, and to apply appropriate controls based on the level of risk identified.
The Bank of Ghana believes that a risk based framework will allow forex bureaus to allocate resources more efficiently while maintaining robust compliance systems. It also ensures that higher risk transactions and relationships receive enhanced scrutiny, reducing vulnerabilities within the financial system.
Under the new rules, forex bureaus must ensure that their internal AML and CFT policies go beyond simply outlining money laundering offences and predicate crimes. The policies must also clearly prescribe sanctions for non compliance with relevant AML, CFT and CPF requirements. This includes internal disciplinary measures for staff as well as mechanisms for reporting breaches to regulatory authorities.
The central bank’s directive underscores the importance of accountability within forex bureaus. By embedding sanctions into internal policies, institutions are expected to foster discipline and reinforce adherence to regulatory standards at all levels of operation.
Promoting a Culture of Compliance
The Bank of Ghana has stressed that it is in the best interest of forex bureaus to entrench a strong culture of compliance. According to the regulator, the new guidelines are designed not only to enforce rules but also to support institutions in building sustainable compliance frameworks that protect their businesses and the wider economy.
A strong compliance culture, the central bank notes, enhances confidence in the foreign exchange market, supports Ghana’s international reputation and helps safeguard the financial system from abuse. Forex bureaus that proactively align their operations with the guidelines are likely to benefit from improved credibility and reduced regulatory risk.
The enforcement of the 2025 AML and CFT guidelines marks a significant shift for Ghana’s forex bureau industry. Operators are expected to invest in staff training, compliance systems and reporting infrastructure to meet the new requirements. While this may increase operational costs in the short term, the Bank of Ghana believes the long term benefits outweigh the challenges.
As regulatory scrutiny intensifies, forex bureaus that fail to comply risk penalties and reputational damage. The new framework signals the central bank’s determination to ensure that the foreign exchange market operates transparently and in line with global standards, reinforcing Ghana’s commitment to combating financial crime.
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