The Bank of Ghana (BOG) and the Financial Intelligence Centre (FIC) have issued a stringent new set of guidelines aimed at fortifying the agency banking network against money laundering, terrorism financing, and proliferation financing.
The “Anti-Money Laundering, Combating the Financing of Terrorism & Combating the Proliferation Financing of Weapons of Mass Destruction (AML/CFT/CPF) Agency Banking Guidelines,” dated September 2025, places direct responsibility on financial institutions for the compliance of their third-party agents.
The guidelines, issued under the Payment Systems and Services Act, 2019 (Act 987) and the Anti-Money Laundering Act, 2020 (Act 1044), come in response to identified systemic weaknesses. The foreword to the document states that examinations “has shown that some activities relating to agency banking pose money laundering, terrorism financing risks such as fraud, poor corporate governance, weak KYC/CDD/EDD policies and procedures, weak internal control measures, poor regulatory reporting, lack of proper record-keeping procedures and lack of training of agents.”
Under the new rules, the Board and Management of a principal financial institution “shall be responsible for the AML/CFT/CPF enforcement and compliance of its agent(s).” This includes conducting and approving risk assessments, demanding half-yearly reports from management, and ensuring robust Service Level Agreements are in place. Principals must also “update its agent’s information to ensure the fitness and propriety of its shareholders, directors, and ultimate beneficiaries.”
A key operational shift requires principals to ensure their agents fully comply with Know Your Customer (KYC) and due diligence procedures, specifically mandating that agents “complies with the Ghana Card Directive, Supervisory Guidance Note, and all AML/CFT/CPF laws.” Furthermore, principals must implement measures for agents to report fraud and suspicious activities to them “within twenty-four hours of occurrence.”
Enhanced monitoring and internal controls are a major theme. Principals are now obligated to “visit the agents’ outlets every six months” to verify compliance. They must also conduct background checks on agents’ employees and ensure their internal audit functions cover agency activities. Data collection is tightened, with processes required for agents to “collect and maintain information (ID number, name, phone number, address and signature), on third-party customers in relation to cash deposits and withdrawals.”
The guideline mandates comprehensive bi-annual training for agents, with programmes to include “AML/CFT/CPF Laws, Regulations, Directives, Notices, Guidelines” and “Money Laundering red flags and suspicious transactions.” Principals must submit their annual training plan to the BOG and FIC by December 31 each year and maintain detailed records of all sessions conducted.
Failure to comply carries significant repercussions. The document states that a principal “shall be liable to appropriate sanctions as prescribed in the Anti-Money Laundering Act 2020 (Act 1044) and the BOG/FIC AML/CFT/CPF Administrative Penalties Guideline, 2022.” The guidelines took effect immediately upon their issue in September 2025.
This sweeping regulatory move aims to secure Ghana’s rapidly expanding digital financial services landscape against illicit financial flows while preserving the financial inclusion benefits of agency banking.
