Ghana was the first country within the West African sub-region to undergo the Second Round of Mutual Evaluation exercise. The evaluation comprised of the assessment of both Technical Compliance and Effectiveness of measures undertaken by the country in respect of its Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT).
Ghana made significant progress under the ‘Technical Compliance’ criterion as relevant laws, mechanisms and processes were identified to be in place. However, Ghana could not demonstrate ‘Effectiveness’ of the laws and other procedures in place thereby qualifying the country to be subjected to ‘Enhanced Follow Up process’ by the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA). Simultaneously, Ghana was listed on the Financial Action Task Force’s (FATF) ‘Grey List’ of countries with significant deficiencies in their AML/CFT regimes.
Ghana was required to submit progress reports on annual basis demonstrating effective measures being implemented to address the identified deficiencies.
Following the outcome of the evaluation, the FATF developed a two (2) year (2018-2020) Action Plan for Ghana to systematically address the gaps identified in its AML/CFT regime particularly to ensure that effective measures are instituted to fight the twin menace.
A number of measures undertaken to demonstrate the effectiveness of the country’s AM/CFT were implemented and accordingly submitted to the FATF under strict timelines and in some cases the FATF noted that Ghana had implemented some of the action items ahead of schedule. This was commended by the FATF as they acknowledged the commitment with which the country was poised to rectify its AML/CFT deficiencies.
Accordingly, at its June 2021 Plenary, the FATF removed Ghana from the list of countries with significant deficiencies in their AML/CFT regime. A statement was subsequently issued by the FATF that ‘financial transactions from and into the country will no longer be subjected to the increased monitoring process’.
Following the news of the exit of Ghana from the FATF Grey List, the European Union (EU) which cited Ghana to be among countries with strategic deficiencies in their AML/CFT would be expected to acknowledge the effective measures the country has put in place to fight money laundering and terrorist financing and accordingly remove Ghana from the blacklisted countries.