The Bank of Ghana has issued a list of red flags to look out for relative to terrorist financing.
The central bank states that persons involved in foreign currency sales and purchases who share a common address and or number, particularly when the address and or number is not the known address and or number of the individuals involved in the transaction is a red flag.
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In addition, the BoG said, Foreign currency sales and purchases by a non-profit or charitable organization, for which there appears to be no logical economic purpose or for which there appears to be no alignment between the stated activity of the organisation and other parties in the transaction is also a red flag.
Also, it can be red a flag when the stated occupation of the customer is inconsistent with the type and level of sales and purchases of foreign currencies.
The other red flags include “Employee [of Foreign Exchange Bureaux] exhibits a lavish lifestyle that cannot be justified by his/her economic circumstances; Employee fails to comply with operating guidelines,; Employee is reluctant to take a vacation.”
These were highlighted in a report by the Bank of Ghana titled “Anti-Money Laundering/Combating the Financing of Terrorism & the Proliferation of Weapons of Mass Destruction (AML/CFT&P) Guidelines for Foreign Exchange Bureaux.”
The report further stated that Foreign exchange bureaux in Ghana are facing increased regulatory scrutiny to strengthen their monitoring and surveillance systems.
The goal is to detect, prevent, and reduce the risks of money laundering, terrorism financing, and proliferation financing.
The report released by the Bank of Ghana said that Foreign Exchange Bureaux are exposed to varying ML/TF&PF risks through unlawful activities with serious financial and reputational damages if they fail to manage these risks adequately.
The report said that indeed well-documented evidence indicates that ML/TF&PF pose major threats to international peace and security which could seriously undermine Ghana’s development and financial stability.
Consequently, it said, Ghana has made concerted efforts to address ML/TF&PF risks.
The enactment of the Anti-Money Laundering Act, 2008 (Act 749); Anti-Money Laundering (Amendment) Act, 2014 (Act 874); Anti-Terrorism Act, 2008 (Act 762); Anti-Terrorism (Amendment Act), 2012 (Act 842); Anti-Terrorism (Amendment Act), 2014 (Act 875); Anti-Money Laundering
Regulations, 2011 (L.I.1987) and the subsequent passage of the Anti-Money Laundering Act, 2020 (Act 1044) has intensified Ghana’s efforts towards the fight against Money Laundering, Terrorism Financing and Proliferation Financing (ML/TF&PF).
The report however noted that Foreign Exchange Bureaux, in particular, have come under sustained regulatory scrutiny to improve their monitoring and surveillance systems with a view to detecting, preventing, and mitigating ML/TF&PF risks.
To that end, a guideline has been introduced to monitor the operations of the Forex Bureaux.
The guideline covers among others the following key areas of any AML/CFT&P programme:
iii. Customer Due Diligence;
vii. Recordkeeping; and
viii. AML/CFT&P employee training programmes.
Diligent implementation of the provisions of these Guidelines will not only minimise the risks faced by Foreign Exchange Bureaux of being used to launder the proceeds of crime but also provide protection against economic and organised crime, reputational and financial risks.
In this regard, Foreign Exchange Bureaux are required to adopt a risk-based approach in the identification and management of ML/TF&PF risks. Foreign Exchange Bureaux shall ensure that AML/CFT&P policies governing their operations do not only prescribe money laundering and predicate offences but also prescribe sanctions for non-compliance with the relevant AML/CFT&P requirements.
“It is, therefore, in the best interest of the Foreign Exchange Bureaux to entrench a culture of compliance which would be facilitated by these Guidelines,” the report said.
