The Bank of Ghana (BoG) and the Financial Intelligence Centre (FIC) have jointly issued a comprehensive Anti-Money Laundering, Combating the Financing of Terrorism, and Combating Proliferation Financing (AML/CFT/CPF) Guideline 2025, tightening regulatory controls across the financial sector including new measures covering cryptocurrencies, virtual asset service providers (VASPs), and fintech innovations.
The 2025 Guideline replaces the 2022 framework and takes immediate effect. It is issued under the Anti-Money Laundering Act, 2020 (Act 1044) and the Banks and Specialized Deposit-Taking Institutions Act, 2016 (Act 930).
Crypto and Digital Asset Oversight
For the first time, the guideline formally brings virtual assets and cryptocurrency activities under Ghana’s anti-money laundering regime. Licensed institutions must identify and assess money laundering or terrorism financing risks linked to virtual assets and virtual asset service providers before launching new products or partnerships.
“All Accountable Institutions shall report suspicious virtual asset activities to the Financial Intelligence Centre within 24 hours,” the guideline directs. It further requires that VASPs suspend or decline transactions lacking full originator or beneficiary information and report such cases immediately to the FIC.
The guideline warns the public that those investing in unregulated VASPs “may lose their investments without any regulatory intervention” should such entities collapse or close down.
Board Accountability and Compliance Culture
The document strengthens governance obligations, mandating bank boards to take ultimate responsibility for AML/CFT/CPF compliance. Boards must approve compliance policies, risk frameworks, and training programmes, receive quarterly compliance reports, and ensure AML officers are independent and well-resourced.
“Entrenching a culture of compliance,” it states, “not only minimizes the risk of being used to launder the proceeds of crime but also protects institutions from reputational and financial loss.”
Stricter Reporting and Sanctions
Under the new rules, banks and other regulated entities are required to file detailed reports — including cash transactions (above GH¢50,000), electronic currency transfers, suspicious activity reports, and fraud incidents — through the BoG’s Online Reporting and Analytics Surveillance System (ORASS) or directly to the FIC.
Failure to comply will attract administrative sanctions as outlined in Act 1044 and Act 930, with penalties extending to both institutions and individuals.
Whistleblower and Fraud Controls
The framework mandates all banks to institute whistleblower policies, guaranteeing employee protection from retaliation, and to develop fraud management systems capable of real-time detection and reporting.
“Fraud is one of the predicate offences of money laundering,” it cautions, adding that institutions must integrate fraud detection into their compliance regimes and immediately report incidents to the Bank of Ghana.
