Bank of Ghana Reissues AML/CFT/PF Penalties Reminder for Regulated Institutions

The Bank of Ghana on 24 August 2026 issued a fresh notice reminding accountable institutions under its supervision that they remain subject to anti-money laundering, counter-terrorist financing and proliferation-financing requirements, and that non-compliance can attract administrative sanctions.

The notice, issued jointly in the context of the Bank of Ghana and the Financial Intelligence Centre’s supervisory mandates, states that regulated accountable institutions are expected to conduct business to high ethical standards and avoid relationships that could facilitate money laundering, terrorist financing or proliferation financing.

Existing sanctions framework remains in force

The notice links back to the existing Bank of Ghana/FIC administrative sanctions schedule rather than introducing a new statutory penalty regime. That schedule, originally published in 2023 under Ghana’s Anti-Money Laundering Act, 2020 (Act 1044) and related rules, sets penalty ranges for institutions and responsible individuals across a range of AML/CFT/PF control failures.

For several institutional breaches, the schedule provides for administrative penalties of not less than 1,000 and not more than 100,000 penalty units. For responsible board members or AML reporting officers in specified cases, penalties can range from 500 to 20,000 penalty units.

The cited breaches include failure to appoint an Anti-Money Laundering Reporting Officer at managerial level with appropriate access to records and staff; failure to notify the Bank of Ghana when the AMLRO position becomes vacant; inadequate resourcing of the AML/CFT/PF function; failure to maintain adequate AML/CFT/PF policies and procedures; failure by the board to approve key compliance policies; and deficiencies in institution-wide money-laundering and terrorist-financing risk assessment frameworks.

Supervisory significance

The 24 August notice is therefore best understood as a supervisory reminder and renewed emphasis on enforcement of existing requirements, not as a newly created penalty schedule. Its publication reinforces that governance, AMLRO independence and resourcing, documented risk assessment, and board-level oversight remain core expectations for institutions supervised by the Bank of Ghana.

For compliance teams, the practical significance is that weaknesses in AML governance and risk-management infrastructure can themselves trigger administrative action even before a specific money-laundering transaction is established.