🇬🇭 Ghana – AML & Sanctions Compliance Guide 2025

📘 Ghana Country Profile

Ghana maintains a developing financial sector with specific AML/CFT requirements. Key regulatory institutions include:

• Bank of Ghana (BoG) - Primary financial regulator and supervisor
• Financial Intelligence Center (FIC) - National AML/CFT authority
• Ministry of Finance - Policy and regulatory oversight
• Ghana Financial Intelligence Center - Financial intelligence and analysis

⚖️ Ghana Regulatory Framework

• Anti-Money Laundering Act, 2020 (Act 1044)
• Bank of Ghana (BoG) AML/CFT Guidelines
• Beneficial Ownership Regulations, 2020
• Anti-Corruption Act, 2020

Key compliance requirements:

• Mandatory KYC/CDD procedures for all customers
• Enhanced due diligence for PEPs and high-risk clients
• 10-year minimum data retention period
• Mandatory STR filing for suspicious transactions

🛡️ Sanctions Regime

Ghana implements UN sanctions and maintains domestic sanctions lists.

• Regular screening against UN and local watchlists
• Immediate asset freeze requirements
• Reporting obligations to FIC
• Compliance with both regional and international sanctions regimes

🔍 Risk Environment

Typologies:

• Corruption and bribery
• Trade-based money laundering
• Cash-based transactions
• Politically exposed persons (PEPs)
• Illegal trade activities

High-risk sectors: Banking, real estate, casinos, money remittance, import/export

📋 Reporting Requirements

Thresholds and Timelines:

• STR (Suspicious Transaction Report) filing: Within 24 hours of suspicion
• CTR (Currency Transaction Report): GHS 500,000 (approx. $40,000)
• PEP reporting: Mandatory for domestic and foreign PEPs
• Annual compliance reports: Due March 31st

Penalties:

• Non-compliance fines: Up to GHS 1,000,000
• License revocation for repeated violations
• Criminal liability for willful non-compliance

🔐 Data Protection & Privacy

• Data Protection Act, 2012 requirements
• Mandatory data localization for financial records
• 10-year retention period for customer records
• Secure storage requirements for sensitive data
• Breach notification within 72 hours

🧩 Compliance Program

• Comprehensive KYC procedures
• Regular staff training programs
• Transaction monitoring systems
• PEP screening and enhanced due diligence
• Regular risk assessments

🧭 Supervisory Trends

• Increased focus on beneficial ownership transparency
• Enhanced scrutiny of cross-border transactions
• Stricter enforcement of KYC requirements
• Regular on-site inspections by BoG

📊 Risk Assessment Framework

Required Elements:

• Customer risk scoring methodology
• Product and service risk assessment
• Geographic risk factors
• Transaction pattern analysis
• Regular risk review cycles (minimum quarterly)

Documentation Requirements:

• Risk assessment methodology documentation
• Risk scoring criteria and thresholds
• Review and approval records

👥 Staff Training Requirements

Mandatory Training Topics:

• AML/CFT laws and regulations
• KYC and CDD procedures
• Sanctions screening
• Red flag indicators
• Reporting obligations

Training Frequency:

• New staff: Within 30 days of joining
• Annual refresher training
• Role-specific training for compliance staff

💻 System Requirements

Recommended Systems:

• Basic transaction monitoring capabilities
• Manual or automated sanctions screening tools
• Customer risk assessment templates
• Document management system
• Basic reporting tools

Key Considerations:

• Systems should support local language requirements
• Ability to generate reports in required formats
• Basic audit trail functionality
• Secure storage for customer documentation
• Compatibility with local reporting requirements

📝 Record Keeping

Documentation Requirements:

• Customer identification records
• Transaction records and supporting documents
• Risk assessment documentation
• Training records and certifications
• Internal audit reports

Retention Periods:

• Customer records: 10 years after relationship ends
• Transaction records: 10 years from date of transaction
• Training records: 5 years
• Audit reports: 10 years

🏦 Financial Sector

Banks & Financial Institutions:

• Enhanced due diligence for correspondent banking
• Special monitoring for high-risk transactions
• Strict wire transfer regulations
• Mandatory reporting of cross-border transactions

Import/Export Sector:

• Special focus on trade transactions
• Enhanced monitoring of large payments
• Specific requirements for trade company beneficiaries

🏢 Other Regulated Sectors

Real Estate:

• Mandatory reporting of cash transactions
• Enhanced due diligence for high-value properties
• Special attention to foreign buyers

Gaming & Casinos:

• Strict monitoring of gaming transactions
• Mandatory reporting of large wins
• Enhanced due diligence for VIP customers

🌍 International Transactions

Key Requirements:

• Enhanced due diligence for cross-border wire transfers
• Mandatory reporting of international transactions above GHS 500,000
• Special attention to transactions with high-risk jurisdictions
• Documentation of foreign exchange transactions
• Compliance with both regional and international sanctions regimes

Correspondent Banking:

• Strict due diligence on foreign correspondent banks
• Regular review of correspondent banking relationships
• Monitoring of nested account activities
• Documentation of foreign bank certifications

🔄 Trade Finance

Documentation Requirements:

• Detailed trade documentation for all transactions
• Verification of shipping documents
• Commodity price verification
• Beneficiary verification

Risk Mitigation:

• Regular review of trade finance patterns
• Enhanced monitoring of high-value transactions
• Special attention to dual-use goods
• Documentation of trade finance controls

⚠️ Common Challenges

Operational Challenges:

• Limited access to reliable customer data
• High volume of cash transactions
• Complex ownership structures
• Language barriers in documentation
• Limited technological infrastructure

Regulatory Challenges:

• Frequent regulatory changes
• Inconsistent enforcement
• Limited regulatory guidance
• Complex reporting requirements

✅ Practical Solutions

Operational Solutions:

• Implement robust data collection processes
• Develop cash transaction monitoring systems
• Create standardized documentation templates
• Invest in translation services
• Build local compliance expertise

Regulatory Solutions:

• Regular regulatory updates and training
• Proactive engagement with regulators
• Documentation of compliance decisions
• Implementation of automated reporting systems

🤝 Best Practices

Communication Strategies:

• Regular meetings with regulatory contacts
• Proactive reporting of issues
• Clear documentation of compliance efforts
• Timely response to regulatory inquiries
• Maintenance of regulatory relationship logs

Examination Preparation:

• Maintain organized compliance documentation
• Conduct regular internal audits
• Prepare executive summaries of compliance programs
• Train staff on examination procedures

📋 Regulatory Reporting

Effective Reporting:

• Establish clear reporting timelines
• Implement quality control for reports
• Maintain reporting logs and acknowledgments
• Document any reporting delays or issues

Relationship Management:

• Designate primary regulatory contacts
• Maintain regulator contact database
• Document all regulatory communications
• Regular review of regulatory relationships

💡 Ghana Compliance Tips

Key Red Flags in Ghana:

• Large cash transactions without clear source of funds
• Complex transaction structures involving multiple jurisdictions
• Unusual cross-border transfers to high-risk countries
• Reluctance to provide complete KYC documentation

Ghana-Specific Considerations:

• Understanding local business practices and cultural norms
• Managing cash-based economy compliance challenges
• Building strong relationships with Ghanaian regulators
• Navigating language requirements (English)

📚 Ghana Regulatory Resources

• Bank of Ghana (BoG) Official Website
• Ghana Financial Intelligence Center (FIC)
• Ghana Ministry of Finance
• FATF Evaluation – Ghana
• UN Security Council Consolidated List