The evolving landscape of AML/CFT regulations: Second half 2025 outlook for financial institutions

The second part of the year 2025 presents a critical period for financial institutions (FIs), especially in Ghana, as the regulatory landscape for Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) becomes more complex and globally interconnected.

Rapid advancements in technology, evolving criminal methods and renewed global standards necessitate proactive, risk-based and technology-driven compliance strategies.

Ghana’s foundation and legislative progress

Ghana has made significant strides in fortifying its AML/CFT regime. Notably, its removal from the EU’s list of high-risk countries in 2022 reflects its dedication to global compliance expectations. At the core of Ghana’s framework are:

• Anti-Money Laundering Act, 2020 (Act 1044): Replacing Act 749, this Act broadens the scope of unlawful activities and introduces the regulation of Virtual Asset Service Providers (VASPs), a crucial response to emerging crypto risks. It also imposes tougher sanctions for violations.
• Anti-Terrorism Act, 2008 (Act 762): Alongside amendments, it supports Ghana’s fight against terrorism financing.

These laws are underpinned by a national commitment to protecting financial integrity and ensuring transparent financial operations.

Role of the Financial Intelligence Centre (FIC)

The FIC remains the central body for receiving and analysing Suspicious Transaction Reports (STRs) in Ghana. Under Act 1044, its mandate has been enhanced to counter money laundering, tax evasion and terrorism financing. Its effectiveness is strengthened by partnerships with domestic and international law enforcement and financial intelligence units.

BoG AML/CFT Guidelines for Foreign Exchange Bureaux (FEBs)

In February 2025, the Bank of Ghana (BoG), in partnership with the FIC, introduced new guidelines for FEBs. These measures reflect a rigorous risk-based approach (RBA) and introduce key obligations:

• AML governance: FEBs must develop robust AML/CFT programmes, complete with internal controls and governance mechanisms.
• Transaction reporting: Cash transaction reports (CTRs) must be filed for transactions exceeding GH¢20,000 (or its foreign equivalent).
• Customer Due Diligence (CDD): CDD now includes Ghana Card verification and inquiries into source/purpose of funds.
• Beneficial ownership identification: Institutions must determine the actual (ultimate) beneficiaries, especially when customers act on others’ behalf.
• Red flag monitoring: High-risk transactions, especially those involving shell companies or high-risk jurisdictions, must be monitored closely.
• Sanctions screening: All customers must be screened against global and domestic sanctions lists.
• Data retention: Records must be kept for at least five years.

Technology and regulatory innovation

As Fintechs, electronic payment systems and cryptocurrencies grow, Ghana’s regulators are ramping up oversight. The BoG is expected to begin regulating cryptocurrencies formally in September 2025. Artificial intelligence (AI), blockchain and machine learning are increasingly seen as essential compliance tools.

International influences: FATF and EU AML Authority

Ghanaian FIs must also keep pace with global developments. Two major international developments are shaping the compliance landscape:

1. FATF reforms (February 2025)

The Financial Action Task Force (FATF) revised its standards with emphasis on:

• Proportionality: Encourages tailored AML/CFT measures that align with actual risk levels, allowing simplified approaches for low-risk customers and promoting financial inclusion.
• Simplified Due Diligence (SDD): For low-risk scenarios, institutions are encouraged to reduce onboarding friction while remaining compliant.
• Use of technology: FATF acknowledges digital identity solutions, RegTech and AI as key tools in compliance and risk monitoring.

Implications for Ghanaian FIs:

• FIs must enhance internal risk assessments and adopt a nuanced RBA that scales controls up or down depending on client risk.
• Invest in RegTech, including AI-based transaction monitoring and digital KYC processes.
• Ensure financial inclusion efforts are not undermined by overly stringent compliance practices.

2. European Union AML Authority (AMLA)

The formation of the EU AMLA marks a significant milestone in global AML supervision. Though primarily EU-focused, its reach will influence global practices.

Key aspects:

• Harmonised standards: AMLA will standardise AML rules across the EU. Ghanaian FIs involved in cross-border transactions or correspondent banking with EU partners must prepare for stricter expectations.
• Information sharing & UBO verification: EU FIUs will enhance cooperation and enforce verification of Ultimate Beneficial Owner (UBO) data, pushing global transparency standards higher.
• Tech emphasis: AMLA advocates for AI and digital tools, indirectly pressuring FIs globally—including those in Ghana—to invest in modern compliance solutions.

What Ghanaian financial institutions must do

To thrive in this evolving ecosystem, Ghanaian banks and financial entities must adopt strategic, tech-enabled and globally aligned approaches. The following are key action areas:

1. Revamp risk assessments

• Update Enterprise-Wide Risk Assessments (EWRAs) regularly to capture new threats, including cybercrime, virtual assets and cross-border vulnerabilities.
• Ensure the RBA framework is responsive and dynamic, not static.

2. Enhance CDD and KYC

• Leverage the Ghana Card: Integrate digital verification processes to confirm identities reliably and quickly.
• UBO identification: Go beyond surface ownership to uncover and verify true beneficial ownership.
• Apply Enhanced Due Diligence (EDD): For high-risk customers or transactions, deploy deep screening and monitoring tools.

3. Adopt RegTech and compliance technology

Manual processes are increasingly unfit for purpose. Ghanaian FIs should:

• Implement real-time monitoring tools: Use AI and ML to detect anomalies and suspicious behaviour.
• Sanctions screening: Adopt systems that auto-update and flag matches with global and internal sanctions lists.
• Digital identity verification tools: Ensure streamlined and secure onboarding through electronic KYC and digital identity solutions.
• Case management systems: Centralise compliance documentation, investigations and reports to improve audit trails and decision-making.

4. Improve data quality and reporting

• Data integrity: Ensure consistent, complete and accurate customer and transaction data.
• Automated STR/CTR filing: Streamline regulatory reporting to improve timeliness and reduce manual errors.

5. Foster a compliance-first culture

• Training and awareness: Regularly train all levels of staff—operations, sales, compliance and executives—on AML/CFT regulations and responsibilities.
• Leadership commitment: Executives must set the tone for compliance by embedding it in institutional values and strategic goals.

6. Strengthen governance and oversight

• Clear policies: Regularly update AML/CFT policies and procedures to reflect evolving risks and regulations.
• Independent compliance function: Ensure the compliance unit has independence, authority and adequate resources.
• Internal audits: Conduct regular, independent assessments of AML/CFT controls and take prompt remedial action.

7. Engage regulators proactively

• Maintain active and transparent communication with the Bank of Ghana, FIC and other relevant bodies.
• Request clarifications when needed and demonstrate proactive compliance through early adoption of new guidelines.

Conclusion

The AML/CFT environment in the second half of 2025 demands vigilance, innovation and agility. For Ghanaian financial institutions, success lies in balancing compliance obligations with business innovation and customer accessibility. By embedding risk-based strategies, investing in emerging technologies and aligning with both local and global regulatory trends, Ghanaian FIs can:

• Strengthen financial crime prevention,
• Maintain access to international financial systems,
• Enhance customer trust, and
• Contribute meaningfully to national and global financial integrity.

About the writer

Bismark is a seasoned compliance and AML/CFT risk management professional with over a decade of banking sector experience. A pioneer in sanctions compliance regulation, he holds the CGSS and CFCS credentials.

He is currently the manager in charge of AML/CFT Monitoring and Reporting at Consolidated Bank Ghana.