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NATIONAL RISK ASSESSMENT OF MONEY LAUNDERING AND TERRORIST FINANCING: REPUBLIC OF GHANA
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A key feature of the NRA is to understand ML/TF risks and in so doing, identify and evaluate threats, vulnerabilities and their impact on the country and that on the economy of Ghana. The NRA process tested the robustness of the current AML/CFT regime in Ghana. The objective is to identify, assess and mitigate ML/TF risks, through adjustments and amendments in the legal and regulatory frameworks. These measures may require direct policy changes. The desired outcomes of the NRA process are to develop a National Strategic AML/CFT Action Plan that will assist in the allocation of AML/CFT resources, as well as, assist in revising or developing guidance for “Accountable Institutions” so as to ensure compliance with the AML/CFT regime.
The NRA process should support the Government of Ghana’s declared fight against money laundering, illicit financial flows and transnational organised crimes. As far as the process is concerned, the World Bank provided the conceptual framework in the form of a national risk assessment tool (including excel templates), gave technical assistance and guided the working groups in the effective use of the tool. All the findings, interpretations, and judgments of the exercise, are solely the work of the working groups in Ghana, and they do not reflect the views of the World Bank. This report was produced entirely by the working groups.
The NRA process in Ghana involved three phases, undertaken between September 2014 and April 2016. This report discusses the last phase, which is the finalisation and recommendations of the Report and the Action Plan. The Mutual Evaluation done on Ghana in the year 2009, revealed several shortcomings in the country’s compliance with the AML/CFT measures. For instance, Financial Institutions did not conduct any CDD on their customers as required by recommendation 5 of the FATF Recommendations. There were no guidelines. There were no guidelines to enable Accountable Institutions fashion out internal rules in compliance with the afore mentioned recommendations. Besides, the Financial Intelligence Centre was not in existence. The situation has however changed as several legislations have been passed to address the shortcomings revealed during the last Mutual Evaluation of Ghana in the year 2009. All the sectors captured in this NRA have acknowledged the fact of the tremendous growth of Ghana’s cash-based economy. As a result many microfinance institutions have emerged, and are operating, thus boosting the internal transfer of money. This has made the financial system vulnerable to ML/TF risks.