The Bank of Ghana (BoG) has provided financial institutions in Ghana with an Anti-Money Laundering (AML), Combating the Financing of Terrorism(FT) and the Proliferation (PF) of Weapons of Mass Destruction guideline to help identify and combat money laundering and terrorism.
The guideline is pursuant to section 52 of Act 1044 and intended to help financial institutions put in place tactic measures that erode ML/TF&PF.
BoG noted that Ghana over the years has experienced substantial growth in the technological space, resulting in a subsequent rise in the engagement of unlawful practices, amongst which money laundering, terrorist financing and proliferation of weapons and mass destruction are inclusive.
“The emergence of technology and the increasing use of digital channels in Ghana, has made it easier for unlawful activities to thrive. To help combat ML/TF&PF therefore, requires that Accountable Institutions (AIs) in Ghana need to have robust Anti-Money Laundering, Combating the Financing of Terrorism and the Proliferation of Weapons of Mass Destruction (AML/CFT&P) regime”.Bank of Ghana
Money Laundering (ML)/TF&PF affects whole economies, and consequently impact negatively on the economic, political and social development, posing serious challenges across the globe, thus the need for AIs to comply with international standards and regulations, as well as the laws and regulations of Ghana to help combat it, BoG added.
“The need for countries to have strong anti-money laundering mechanisms, coupled with the enhancement of transparent financial integrity cannot therefore be over-emphasized.”BoG
The AML/CFT&P guidelines cover a range of areas, including Customer Due Diligence (CDD), Risk Assessment and Management, Reporting of Suspicious activities, and Training and Awareness.
Constituents of the Guideline Further Explained
With regards to CDD, BoG noted that AIs undertake CDD pursuant to section 30 of Acts 1044 in identifying and verifying their customers and beneficiaries. AIs, however, BoG added, are not permitted to operate anonymous accounts or accounts in fictitious names.
Risk assessment and management is another area highlighted by BoG in its guildeline, requiring that AIs conduct a risk assessment on the customer by identifying and assessing the risks the business reasonably expects to face from ML/TF&PF. A programme is then structured to minimize risks identified.
Continuing on how AIs shoud report suspicious activities, BoG indicated it is the responsibility of AIs to ensure that the Anti-Money Laundering Reporting Officer(AMLRO), who shall be in charge of the process has access to all information central to effective execution of his role.
“AIs shall ensure that the AMLRO has access to all information that may be of assistance to him/her in consideration of a suspicious or unusual transaction/activity report.”BoG
Again with regards to training, BoG noted that training programmes developed be current and relevant, employees are updated on new developments with regards to training, employees understand how their institution contribute to fighting ML/TF/PF, training programmes be consistent with the AI’s size, resources type of operation, just to mention but a few and even more emphatically, be developed under the guidance of the AMLRO and Senior Management.
“Ensure that ongoing training programmes on ML/TF&PF are current and relevant…
“The employee training programme is required to be developed under the guidance of the AMLRO in collaboration with the Senior Management.”Bank of Ghana
The guideline also outlines specific requirements for financial institutions to follow when dealing with high-risk customers or transactions, and provides guidance on how to identify and report potential money laundering and terrorism financing activities.
Overall, the AML/CFT&P guidelines are designed to help financial institutions in Ghana protect against abuse of the financial system for illicit purposes, and to support the efforts of law enforcement agencies in investigating and prosecuting money laundering and terrorism financing cases.