FATF Mutual Evaluation Scorecard

Ghana

Relevant authorities have a good understanding and recognition of most of Ghana’s ML/TF risks, as demonstrated by the national risk assessment (NRA), but a documented national AML/CFT policy has yet to be developed at the time of the Mutual Evaluation Report (MER).
Ghana’s TF risks are generally moderate. However, certain issues in adjacent countries potentially increase its vulnerability to terrorism and TF. Ghana has developed a national anti-terrorism strategy, but needs a strategy directly addressing TF.
Banks have a good understanding of ML/TF risks, with strong mitigation efforts. However, a significant gap is evident in terms of supervision, and the level of understanding and the implementation of preventive measures between banks and other FIs, as well as designated non-financial businesses and professions (DNFBPs).
There needs to be a comprehensive review of the (non-profit organizations) NPO sector, and to integrate registration and licensing into a legal framework.

In Ghana’s 2018 FUR, two (2) Recommendations were re-rated due to progress made based on MER deficiencies. Early in 2018, Ghana revised its AML/CFT Guidelines on obtaining beneficiary information for wire transfers and on requiring FIs to assess risk if third parties relied on are located in another country, which largely addressed deficiencies for R16 and R17.
Another FUR was published in 2021, which led to the downgrade of R15 and R21. FATF made revisions to R21 criteria in February 2018, which clarified anti-tipping off previsions. Although the revised guidelines covered the provisions, certain prohibitions needed to be expressly stipulated to constitute full compliance, thus the R21 downgrade. Additionally, FATF also revised R15 in October 2019 to specify requirements applicable to virtual assets and virtual asset providers (VASPs). While Ghana has demonstrated compliance to several requirements of R15, some key and fundamental criteria are still missing, which effectively downgraded R15.
Further improvements were made to the NPO sector, such as completing the risk assessment, improving the regulatory framework and national policy, and risk-based supervision, as well as to the maintenance of statistics and the application of financial sanctions, leading to higher ratings for R8, R33 and R35 in 2022.