Key Takeaways.
1) Ghana’s AML framework is anchored in the Anti-Money Laundering Act, 2020 (Act 1044), and supported by complementary laws.
2) Financial institutions and designated businesses must implement robust Customer Due Diligence (CDD) and ongoing monitoring processes.
3) Suspicious Transaction Reports (STRs) and Currency Transaction Reports (CTRs) must be submitted to the Financial Intelligence Centre (FIC).
4) Non-compliance can result in administrative fines, license suspension, asset freezing, confiscation, and criminal liability for both institutions and responsible officers.
Introduction.
Ghana’s financial system is advancing with digital innovations like GhanaPay and mobile money, as well as the regulatory framework via the Bank of Ghana (BoG) and the Financial Intelligence Centre (FIC).
Recent frameworks emphasize risk-based AML compliance for banks, fintechs, and financial institutions, ensuring that institutions conduct effective customer verification and report suspicious transactions to the FIC promptly
This article provides a complete breakdown of AML regulations, key obligations, recent updates, and penalties under the AML Act in Ghana.
What is anti-money laundering?
Anti-Money Laundering (AML) refers to the set of laws, policies, and procedures designed to detect and prevent criminals from transforming illegal funds into legitimate income.
In Ghana, anti-money laundering regulations are structured to combat money laundering, terrorist financing, and related financial crimes. For financial institutions in Ghana, adhering to AML regulations means implementing robust systems that integrate KYC/AML procedures, transaction monitoring, reporting obligations, and governance controls.
What is the regulatory framework in Ghana?
The regulatory framework is a system of rules and regulations that governs the behavior, operations, and compliance of individuals within a specific industry. These structures include:
1. The Anti-Money Laundering Act, 2020 (Act 1044)
The Anti-Money Laundering Act, 2020 (Act 1044), is the cornerstone of Ghana’s AML rules and regulations. This law consolidates and strengthens Ghana’s AML framework.
The AML Act in Ghana establishes preventive measures, sanctions, and supervisory powers. It also aligns Ghana with international standards, including recommendations from the Financial Action Task Force (FATF).
Key objectives of the AML Act in Ghana include:
1) Preventing the laundering of proceeds of crime
2) Combating terrorist financing
3) Establishing compliance obligations for regulated entities.
Other regulatory frameworks supporting Ghana’s AML Act
While the Anti-Money Laundering Act, 2020 (Act 1044) is the primary law governing AML compliance, Ghana’s framework is strengthened by several complementary statutes. These laws include:
1) Proceeds of Crime Act, 2009 (Act 759)
The Proceeds of Crime Act focuses on identifying, tracing, confiscating, and recovering assets obtained from criminal activity. This law complements the AML Act by ensuring that even if money laundering is detected, offenders do not retain the financial benefits of their crimes
The key objectives of the Proceeds of Crime Act are
1) Prevent criminals from benefiting from unlawful activities
2) Provide mechanisms for asset confiscation
3) Enable property freezing and forfeiture orders.
2) Anti-Terrorism Act, 2008 (Act 762)
The Anti-Terrorism Act, 2008 (Act 762), addresses terrorism and terrorist financing, which are core components of modern AML frameworks. This is why global compliance systems are commonly referred to as Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT)
Under this act, it is a criminal offense to provide, collect, or make funds available for terrorist purposes. The law empowers authorities to freeze assets, block accounts, investigate suspicious financial flows, and prosecute individuals or entities involved in terrorist financing.
This act strengthens Ghana’s compliance with global standards set by bodies like the Financial Action Task Force (FATF).
Who does the AML regulation apply to in Ghana?
Under Ghana’s AML framework, compliance is mandatory for a wide range of institutions classified as accountable or reporting entities under the Anti-Money Laundering Act, 2020 (Act 1044). These entities are legally required to implement AML controls, meet reporting obligations, and conduct proper customer verification.
The following financial entities are subject to AML obligations:
1) Commercial banks
2) Savings and loans companies
3) Microfinance institutions
4) Payment service providers
5) Fintech companies
What are the core AML obligations in Ghana?
1) Customer Due Diligence (CDD)
Customer due diligence refers to the process that businesses and financial institutions use to identify, verify, and assess the risk profile of their customers before and during a business relationship. Customer due diligence forms the foundation of KYC/AML compliance. The main goal of customer due diligence procedures is to prevent criminals from using legitimate institutions to disguise illicit funds.
The CDD process involves
1) Customer Identification: Collecting basic information such as name, address, and government-issued identification to identify the customers as who they really claim to be
2) Customer Verification: This is the process of verifying the authenticity of documents provided by customers against reliable and independent sources.
3) Beneficial Ownership Identification: For corporate clients, institutions must identify the ultimate beneficial owners (UBOs), who are individuals who ultimately own or make the decisions in the organization.
4) Ongoing Monitoring: Institutions must continuously monitor transactions to ensure they align with the customer’s risk profile.
2) Record-Keeping Obligations
Businesses must retain customer records, transaction histories, and supporting documentation for a prescribed period under Ghanaian law.
These AML requirements ensure that records are accessible to regulators and law enforcement when needed. Maintaining accurate records is a core obligation under AML regulations and is essential for demonstrating compliance during regulatory audits.
3) Reporting Obligations
Reporting obligations are a central pillar of Ghana’s AML framework under the Anti-Money Laundering Act, 2020 (Act 1044). These obligations require businesses to report certain transactions and activities to the Financial Intelligence Centre (FIC).
Reporting obligations transform AML compliance from a passive system into an active detection mechanism. By requiring institutions to file Suspicious Transaction Reports (STRs) and Currency Transaction Reports (CTRs), Ghana’s regulatory framework strengthens transparency, supports law enforcement investigations, and helps prevent the misuse of the financial system for criminal or terrorist purposes.
Read more: What are suspicious transaction reports?
4) Internal Controls & Governance
Strong internal controls are a mandatory requirement for businesses under the Anti-Money Laundering Act, 2020 (Act 1044). These financial institutions must establish and maintain effective AML policies, procedures, and governance structures to prevent, detect, and report money laundering and terrorist financing activities.
A structured KYC/AML compliance framework integrates governance oversight, monitoring systems, employee accountability, and internal controls to meet statutory AML requirements.
Ultimately, strong internal controls and governance structures demonstrate regulatory commitment and protect the integrity of Ghana’s financial system.
What are the penalties for non-compliance with AML regulations?
Penalties for violating Ghana’s AML framework are set out under the Anti-Money Laundering Act, 2020 (Act 1044) and related laws. Non-compliance may result in administrative or criminal consequences depending on the severity of the offense.
1) Administrative Sanctions
Regulatory authorities and the Financial Intelligence Centre (FIC) may impose penalties such as monetary fines, compliance directives, restrictions on business activities, or even suspension of licenses.
Administrative penalties may apply for failures such as inadequate internal controls, failure to file required reports, or weak customer due diligence systems.
2) Corporate and Individual Liability
Under Ghana’s AML laws, both the institution and responsible officers, such as directors or compliance officers, may be held liable. This means accountability can extend to individuals if negligence or intentional misconduct is proven.
3) Asset Freezing and Confiscation
Where funds are linked to criminal activity, Regulatory bodies may freeze accounts, restrict access to assets, or initiate confiscation proceedings
These measures may also be supported by provisions under the Proceeds of Crime Act, 2009 (Act 759).
Bottom line.
Ghana’s AML framework continues to strengthen in response to digital innovation and evolving financial crime risks.
The Anti-Money Laundering Act, 2020 (Act 1044), supported by complementary legislation, establishes clear compliance, reporting, and governance obligations for regulated entities. Ultimately, compliance with AML rules protects institutions, customers, and the integrity of Ghana’s financial system.
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FAQ’s
1) What are the new AML regulations for 2026?
Ghana’s core AML framework remains based on the Anti-Money Laundering Act, 2020 (Act 1044). The main updates focus on stronger enforcement, enhanced risk-based supervision, improved transaction monitoring, and increased compliance expectations for financial institutions and fintechs.
No entirely new standalone AML law has replaced the existing act.
2. What are the legislative changes in Ghana in 2026?
In 2026, legislative developments related to AML mainly involve strengthening regulatory oversight, especially in digital finance and compliance enforcement.
The focus has been on improving the implementation of existing laws rather than introducing a completely new AML statute.