The Bank of Ghana has issued formal anti-money laundering and combating the financing of terrorism guidelines, prepared jointly with the Financial Intelligence Centre, for foreign exchange bureaux operating in the country, with the central bank designated as the supervisory body responsible for overseeing sector-wide compliance. The guidelines are issued under the Anti-Money Laundering Act, 2020 (Act 1044), the principal legislation governing AML/CFT obligations across the Ghanaian financial system.

Foreign exchange bureaux buy and sell foreign currency for individuals and businesses in Ghana.

RISK-BASED APPROACH REQUIRED ACROSS THE SECTOR

Under the new guidelines, all licensed forex bureaux are required to adopt a risk-based approach to AML/CFT compliance, in identifying and managing money laundering, terrorist financing and proliferation financing risks. The framework mandates customer due diligence before every transaction: bureaux must identify and verify customers for all sales and purchases of foreign currency, using the Ghana Card for Ghanaians and the Non-Citizen Card or passport for foreign nationals, ask about the purpose of the transaction and the source of funds, and establish the true identity of the ultimate beneficiary where a customer acts for another person.

Bureaux must also have a written policy to monitor, identify and report suspicious transactions, taking account of the frequency, volume and size of customer transactions. Each bureau's Anti-Money Laundering Reporting Officer, whose appointment must be approved by the Bank of Ghana, monitors key customer relationships and reports to directors or management. Where reasonable grounds for suspicion arise, operators must file suspicious transaction reports with the Financial Intelligence Centre within 24 hours, and all foreign currency sales and purchases of GHS20,000 or more must be reported to the FIC as cash transactions. Bureaux must also keep customer and transaction records for at least five years and make them readily available to the Bank of Ghana, the FIC or other competent authorities on request.

OUTSOURCING RESTRICTIONS AND SUPERVISORY EXPECTATIONS

The guidelines restrict outsourcing: bureaux may not outsource any AML/CFT&P function to a third party without the prior approval of the Bank of Ghana.

The guidelines also require bureaux to set out in their AML/CFT&P policies the sanctions for non-compliance.