Ghana Exits FATF Grey List

Ghana was the first country within the West African sub-region to undergo the Second Round of Mutual Evaluation exercise. The evaluation comprised an assessment of both the Technical Compliance and Effectiveness of measures undertaken by the country in respect of its Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) regime.

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, qualifying the country for an ‘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 annually, 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 effective measures were instituted to fight the twin menace.

A number of measures undertaken to demonstrate the effectiveness of the country's AML/CFT regime were implemented and submitted to the FATF under strict timelines, and in some cases the FATF noted that Ghana had implemented some action items ahead of schedule — commended as evidence of the country's commitment to rectifying 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, stating that financial transactions from and into the country would no longer be subjected to the increased monitoring process.

Following the news of Ghana's exit from the FATF Grey List, the European Union (EU), which had cited Ghana among countries with strategic deficiencies in their AML/CFT regimes, would be expected to acknowledge the effective measures the country has put in place and accordingly remove Ghana from its blacklisted countries.

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