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National Risk Assessment of Money Laundering And NATIONAL RISK ASSESSMENT ON MONEY LAUNDERING AND TERRORIST FINANCING REPUBLIC OF GHANA CONTENTS ACRONYMS......................................................................................................................................................... 4 INTRODUCTION ................................................................................................................................................ 1 OBJECTIVES ...................................................................................................................................................... 1 METHODOLGY .................................................................................................................................................. 1 LIMITATIONS...................................................................................................................................................... 4 EXECUTIVE SUMMARY.................................................................................................................................. 5 CONCLUSION .................................................................................................................................................... 8 SECTION 1- MONEY LAUNDERING (ML) RISK ASSESSMENT ......................................................... 9 1.1 THREAT ASSESSMENT ...................................................................................................................... 9 1.2 NATIONAL VULNERABILTY ASSESSMENT ................................................................................ 19 1.3 BANKING SECTOR ASSESSMENT ................................................................................................ 61 1.4 SECURITIES ......................................................................................................................................... 77 1.5 INSURANCE SECTOR ...................................................................................................................... 111 1.6 OTHER FINANCIAL INSTITUTIONS ............................................................................................ 130 1.7 DESIGNATED NON- FINANCIAL BUSINESSES AND PROFESSIONS (DNFPBs) .......... 141 1.8 FINANCIAL INCLUSION ASSESSMENT ..................................................................................... 159 SECTION 2- TERRORIST FINANCING (TF) RISK SUMMARY ......................................................... 172 2.1 INTRODUCTION ................................................................................................................................ 172 2.2 CONCLUSION- TERRORIST FINANCING ASSESSMENT ..................................................... 182 2.3 RECOMMENDATIONS- TERRORIST FINANCING ASSESSMENT ..................................... 183 3. CONCLUSION- NATIONAL RISK ASSESSMENT ON M/L & T/F .............................................. 184 4. MAIN RECOMMENDATIONS- NATIONAL RISK ASSESSMENT ON M/L & T/F .................. 186 5. BIBLIOGRAPHY ........................................................................................................................................ 188 II The World Bank role was limited to the deployment of the excel template, provision of technical assistance and guidance in the effective use of the excel template. Data was collected and populated into the template. Findings, interpretations, and judgments of the exercise was solely the work of the Working Groups and do not reflect the views of the World Bank III ACRONYMS AIs _ “ACCOUNTABLE INSTITUTION” AML _ ANTI MONEY LAUNDERING AMLRO _ ANTI MONEY LAUNDERING REPORTING OFFICER BOG _ BANK OF GHANA CDD _ CUSTOMER DUE DILIGENCE CEO _ CHIEF EXECUTIVE OFFICER CFT _ COUNTERING/COMBATTING THE FINANCE OF TERRORISM CMOs _ CAPITAL MARKET OPERATORS COs _ COMPLIANCE OFFICERS CTRs _ CASH TRANSACTION REPORT CUs _ CREDIT UNIONS DNFBPs _ DESIGNATED NON FINANCIAL BUSINESSES AND PROFESSIONS E I _ EXECUTIVE INSTRUMENT ECOWAS _ ECONOMIC COMMUNITY OF WEST AFRICAN STATES FATF _ FINANCIAL ACTION TASK FORCE FIC _ FINANCIAL INTELLIGENCE CENTRE FNGOs _ FINANCIAL NON GOVERNMENTAL ORGANISATIONS FOREX _ FOREIGN EXCHANGE IV FT _ FINANCING OF TERRORISM GBA _ GHANA BAR ASSOCIATION GDP _ GROSS DOMESTIC PRODUCT GHAMFIN _ GHANA MICROFINANCE INSTITUTION NETWORK GIABA _ INTERGOVERNMENTAL ACTION GROUP AGAINST MONEY LAUNDERING IN AFRICA GNP _ GROSS NATIONAL PRODUCT GRA _ GHANA REVENUE AUTHORITY GREDA _ GHANA REAL ESTATE DEVELOPERS ASSOCIATION GSE _ GHANA STOCK EXCHANGE IBA _ INTERNATIONAL BAR ASSOCIATION ICAG _ INSTITUTE OF CHARTERED ACCOUNTANTS GHANA Ids _ IDENTIFICATION IMF _ INTERNATIONAL MONETARY FUND KYC _ KNOW YOUR CUSTOMER L I _ LEGISLATIVE INSTRUMENT LEAs _ LAW ENFORCEMENT AGENCIES MFCs _ MICROFINANCE COMPANIES MFIs _ MICROFINANCE INSTITUTIONS ML _ MONEY LAUNDERING ML/TF _ MONEYLAUNDERING/ TERRORIST FINANCING V MLs _ MONEY LENDERS MOF _ MINISTRY OF FINANCE MVTS _ MONEY VALUE TRANSFER SERVICES NBFI _ NON BANK FINANCIAL INSTITUTION NGOs _ NON GOVERNMENTAL ORGANISATIONS NIC _ NATIONAL INSURANCE COMMISSION NLA _ NATIONAL LOTTERY AUTHORITY NPOs _ NON PROFIT ORGANISATIONS NRA _ NATIONAL RISK ASSESSMENT OECD _ ORGANISATION FOR ECONOMIC COOPERATION DEVELOPMENT OFAC _ OFFICE OF FOREIGN ASSETS CONTROL OFIs _ OTHER FINANCIAL INSTITUTIONS PEPs _ POLITICALLY EXPOSED PERSONS PMMC _ PRECIOUS MINERALS MARKETING COMPANY PNDCL _ PROVISIONAL NATIONAL DEFENCE COUNCIL LAW RCBs _ RURAL AND COMMUNITY BANKS RGD _ REGISTRAR GENERAL DEPARTMENT S&Ls _ SAVINGS AND LOANS COMPANIES SC&Es _ SUSU COLLECTORS AND ENTERPRISES SDD _ SIMPLIFIED DUE DILIGENCE VI SEC _ SECURITIES AND EXCHANGE COMMISSION SMEs _ SMALL AND MEDIUM SKILL ENTERPRISES SRO _ SELF REGULATORY ORGANISATION STR _ SUSPICIOUS TRANSACTION REPORT TF _ TERRORIST FINANCING WB _ WORLD BANK VII INTRODUCTION In recent years the twin menace of Money Laundering and Terrorist Financing (ML/TF) have assumed alarming proportions putting at risk the global Financial Systems. Criminals over the years have concealed their illicit proceeds by investing in legitimate businesses through a number of schemes in the Bank Financial Institutions and Non-Bank Financial Institutions (FIs) and the Designated Non-Financial Businesses and Professions (DNFBPs). It is estimated by the International Monetary Fund (IMF) that the magnitude of money laundered in the world is about 3-5% of the world’s Gross Domestic Product (GDP) (source: IMF Report, 2008). The Financial Action Task Force (FATF) 40 Recommendations set out a comprehensive and consistent framework of measures which countries should implement in order to combat ML/TF as well as the financing of proliferation of weapons of mass destruction. Countries have diverse legal, administrative and operational framework and different financial systems and so cannot implement the same measures to counter these threats. The FATF Recommendations, therefore, set an international standard, which countries should implement through measures adapted to their peculiar circumstances (Revised FATF Recommendations 2012). Recommendation 1 of the Revised FATF Recommendations (2012) and paragraphs 3-6 of its Interpretative Note (INR 1), in particular, outline general principles that may serve as a useful framework in assessing ML/TF risks at the national level. Consequently, the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA) directed all member States at its plenary in Niamey, Niger in May 2014, to undertake and complete their respective National Risk Assessments (NRA) before the next round of Mutual Evaluation commences in September 2016. The National Risk Assessment (NRA) is, therefore, intended to provide guidance on the conduct of identifying and assessing threats and vulnerabilities of a country at national level, and it relates especially to key requirements set out in Recommendation 1. This Recommendation outlines general principles that may serve as a useful framework in assessing ML/TF risks at the national level. OBJECTIVES The objectives of the NRA were to; a) Determine the level of vulnerability of the economic and financial sectors to ML/ TF b) Determine and understand the weaknesses in the legal framework, by considering the criminal and administrative justice system, and existing preventive systems; and c) Appreciate the best way to allocate resources for the prevention, investigation and prosecution of ML and TF. METHODOLGY 1 This report discusses findings from Ghana‘s national ML/TF risk assessment, and was conducted as a self-assessment by Ghana through various working groups, using the World Bank’s National Risk Assessment tool. Working Group members involved in the drafting of this report include representatives from: the National Security Council Secretariat, Financial Intelligence Centre(FIC),Attorney General’s Department, Ghana Police Service, Narcotic Control Board, Economic and Organised Crime Office, Ghana Revenue Authority, Ghana Immigration Service Ghana Airport Authority, Representatives of Regulatory Bodies ( Bank Of Ghana, National Insurance Commission, Securities and Exchange Commission, National Pensions Regulatory Authority, Representatives of Compliance Officers from Banks, Insurance Brokers, Security Brokerage Firms, Forex Bureau Operators, Mobile Money Operators, Real Estate Representatives, Casino Operators, Non Profit Organisations, Car Dealers, Gate Keepers, Chamber Of Commerce, Micro Finance Network Representatives. It was agreed that the composition of Working Groups should include members of the Private Sector since their involvement
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