As global scrutiny over money laundering and terrorist financing intensifies, countries in West Africa are facing mounting pressure to strengthen their regulatory frameworks.

However, a lack of standardisation and harmonisation across the region threatens to undermine these crucial efforts.

While economic powerhouses like Ghana and Nigeria have made significant strides in implementing the Financial Action Task Force’s (FATF) recommendations on ultimate beneficial ownership (UBO) transparency, other nations in the region remain far behind.

“We have disparities or differences in the level of compliance across the West African countries. For example is what we have in Ghana compared to other countries Nigeria, Sierra Leone and Gambia,” said Benjamin Kyei Armoo, the Chief Compliance Officer at GCB Bank.

“This lack of a standardised approach creates opportunities for regulatory arbitrage and leaves gaping holes in the regional financial system,” he told the B&FT on the sidelines of a high-profile Compliance Forum in Dakar, Senegal, organised by the African Export-Import Bank (Afreximbank), in partnership with the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA).

These experts, who spoke on the second panel under the theme ‘The Implications of Ultimate Economic Beneficiary Identification’ provided participants with a high-level presentation of the main improvements and the motivation for these improvements initiated by the FATF recommendations.

The main aim of the panel was to draw the attention of participants to the main areas of intervention for the effective and efficient implementation of the FATF standards.

Other members of the panel were Chantal Bodet, Analyste Opérationnelle, FIA Côte d’lvoire; Thierno Deme, Deputy Director, Department of Supervision of the Non-Bank Financial Institutions, The Central Bank of West African States (BCEAO); and Alioune Niokhor Diouf, Director of Legal Affairs, FIA. Nicolas Négoce, Senior Reporter, BBC (West African Affairs Specialist), moderated the panel.

The disparity has prompted calls for the creation of a dedicated West African Compliance Officers Association or a body (Africa Compliance Institute) to coordinate and align compliance practices across the sub-region.

Experts argue that such an institution could help ensure a consistent level of anti-money laundering and counter-terrorist financing (AML/CFT) implementation rather than leaving individual countries to navigate the complex landscape on their own.

“We need to harmonise the regulatory environment across West Africa. Without a cohesive, regional approach, we will continue to see uneven progress and vulnerability to illicit financial flows,” Felix Obiamalu, the General Counsel of the Nigerian Financial Intelligence Unit, added during an interaction.

The issue is particularly pressing as West African nations grapple with the implications of the FATF’s revised Recommendation 24, which encourages countries to adopt measures to prevent corporate structures from being misused for criminal purposes.

While Ghana and Nigeria have already implemented laws and registries for UBO information, the accessibility and effectiveness of these systems vary widely across the region.

Already, Africa has been hemorrhaging billions of dollars annually due to illicit financial flows (IFFs). Over the past 50 years, the continent is estimated to have lost more than US$1 trillion in these illegal outflows, a staggering sum that nearly equals the total official development assistance it has received during the same period.

Current estimates suggest that the continent continues to lose over US$50 billion each year to IFFs. However, these figures may be conservative due to the lack of accurate data for many African countries and the difficulty in tracking covert activities like bribery and drug trafficking.

The actual annual loss to IFFs is likely significantly higher. “It is not just about having the regulations in place. It is about ensuring a consistent level of implementation and enforcement so that we’re not leaving any loopholes for illicit actors to exploit,” Mr. Armoo further stated.

Experts point to the successful collaboration between the GIABA and individual countries as a potential model for a more coordinated regional approach. However, they caution that GIABA’s current role as a policy-oriented body may not be sufficient to drive the necessary operational changes.

“GIABA is good at providing high-level guidance, but we need an institution that can actually go into the field and ensure compliance is being carried out properly. That’s where a dedicated West African Compliance Officers Association could make a real difference,” Mr. Obiamalu added.

The Afreximbank Compliance Forum

The Afreximbank Compliance Forum, which was organised in partnership with the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA) was sponsored by some banks including Vista Bank, GCB Bank, Wave, Rawbank, SUNU Group and compliance system providers such as Lexus Nexis, Elucidate, Finanstra and Llyod’s List Intelligence, Consortix, and Vneuron.

The Forum focused on the Financial Action Task Force’s (FATF) requirements for identifying Ultimate Beneficial Owners (UBOs) and their far-reaching implications for trade facilitation.

The FATF, an intergovernmental organisation, sets international standards to prevent money laundering, terrorist financing, and other threats to the integrity of the global financial system. One of its critical mandates is to identify and verify UBOs to ensure transparency and accountability in financial transactions.

Additionally, the Forum explored the transformative role of Artificial Intelligence (AI) in compliance processes, address strategies for African countries to make the necessary reforms to be removed from the FATF’s grey list and showcase the latest compliance technologies.

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