The Bank of Ghana has issued formal anti-money laundering and combating the financing of terrorism guidelines for foreign exchange bureaux operating in the country, designating itself as the supervisory body responsible for overseeing sector-wide compliance. The guidelines, published as Notice No. BG/GOV/SEC/2025/04, take effect under sections 52(1) and (5) of Act 1044, the principal legislation governing AML/CFT obligations across the Ghanaian financial system.
Foreign exchange bureaux occupy a significant and structurally distinctive position in Ghana's financial system, providing currency conversion and remittance services to a broad and varied customer base that includes individuals, diaspora clients, and small businesses with limited or no access to conventional commercial banks. Their extensive reach, high transaction volumes, and predominantly cash-based operational model have long made them a priority concern for financial intelligence authorities seeking to close gaps in the country's AML/CFT framework and bring the sector into alignment with international standards.
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, calibrating the intensity of their controls to reflect the nature, scale, geographic footprint, and complexity of their individual business activities. The framework mandates robust customer due diligence procedures, encompassing the identification and verification of clients at onboarding, the assessment of beneficial ownership structures where applicable, and the application of enhanced due diligence measures for higher-risk customer relationships or transaction types.
Bureaux must also implement and maintain ongoing transaction monitoring capabilities capable of generating timely alerts for activity that deviates from established patterns or expected client behaviour. The guidelines require that such alerts be reviewed promptly by appropriately qualified personnel and that the outcomes of those reviews be documented. Where reasonable grounds for suspicion arise, operators must file suspicious transaction reports with the relevant financial intelligence authority in accordance with the existing requirements of Act 1044. Comprehensive record-keeping obligations are also reinforced, with firms expected to retain documentation sufficient to enable regulators and law enforcement agencies to reconstruct transactions in full if required.
OUTSOURCING RESTRICTIONS AND SUPERVISORY EXPECTATIONS
One of the most operationally significant provisions in the notice is its restriction on the delegation of AML/CFT functions. Forex bureaux are explicitly prohibited from outsourcing these responsibilities to third-party service providers unless they have first obtained written approval from the Bank of Ghana. The provision is designed to ensure that accountability for compliance remains unambiguously seated within the licensed entity itself, and that any approved third-party arrangements are subject to adequate oversight, contractual safeguards, and ongoing monitoring by the central bank.
The Bank of Ghana stated that the guidelines are intended to bring the supervisory regime for forex bureaux into full conformity with the standards issued by the Financial Action Task Force. Non-compliance with the requirements set out in the notice is expected to attract proportionate supervisory action, which may include financial penalties, enhanced monitoring, or licence review. The issuance of Notice No. BG/GOV/SEC/2025/04 forms part of a broader and sustained programme of financial sector regulatory reform being pursued by the central bank to reinforce the integrity of Ghana's foreign exchange market and the wider financial system.