Regulatory Influencer: Ghana Launches New AML Policy for 2025-2029

On September 1, 2025, the Bank of Ghana published its National Anti-Money Laundering, Counter-Terrorism Financing, and Counter-Proliferation Financing (AML/CFT/CPF) Policy and Action Plan for 2025-2029, a five-year strategic framework that re-defines the country’s approach to financial integrity and compliance.

The policy sets out a strategic roadmap to strengthen Ghana’s AML/CFT/CPF regime, with a focus on legal and regulatory reforms, institutional capacity building, inter-agency coordination and private sector engagement. Its objectives include preventing, detecting and prosecuting financial crime, safeguarding the stability and reputation of Ghana’s financial and non-financial sectors, and ensuring full compliance with Financial Action Task Force (FATF) standards.

The framework establishes five strategic goals:

• Enhancing the AML/CFT/CPF legal framework in line with international standards.
• Improving investigations, prosecutions, convictions and asset recovery related to ML/TF/PF.
• Strengthening domestic and international cooperation.
• Enhancing national AML/CFT/CPF databases and information sharing.
• Building capacity and awareness across both public and private sector entities.

The bigger picture

The new framework mainly builds on the findings of Ghana’s 2024 National Risk Assessment (NRA), as well as its sectoral Risk Assessment on Virtual Assets and Virtual Asset Service Providers (VAs/VASPs). The 2024 NRA found Ghana’s overall ML risk to be “Medium” and TF/PF risks to be “Low”, an improvement driven by recent reforms such as the Anti-Money Laundering Act, 2020 (Act 1044) and the Companies Act, 2019 (Act 992). However, the assessment highlighted persistent system-wide vulnerabilities, including uneven supervision across sectors, limited transparency of beneficial ownership data and resource constraints among competent authorities, all of which affect how effectively financial institutions and virtual asset service providers are monitored and supported in meeting AML/CFT obligations.

The VAs/VASPs assessment added urgency to this shift. It identified high ML/TF vulnerabilities in digital asset ecosystems, particularly in wallet security, fiat conversion and regulatory oversight. The study recommended dedicated regulation for VASPs, stronger cybersecurity standards and greater coordination between regulators, law enforcement and the private sector.

Together, these assessments made clear that Ghana’s risk landscape is evolving from traditional predicate crimes toward digitally driven and cross-sectoral threats. The 2025-2029 policy therefore focuses on risk-based supervision, stronger inter-agency coordination, and new oversight for VASPs and high-risk sectors, marking a decisive move from reactive compliance to proactive financial-crime prevention.

Key considerations

The key implementation considerations under the policy include:

• Risk-based supervision at scale: Regulators such as the Bank of Ghana (BoG), Securities and Exchange Commission (SEC), National Insurance Commission (NIC), and Gold Board will need to embed risk-based supervision frameworks across financial and non-financial sectors.
• Integration of VASPs and new sectors: The inclusion of virtual asset service providers reflects Ghana’s recognition of crypto-related ML/TF risks and its intent to regulate the sector in line with FATF Recommendation 15.
• Beneficial ownership transparency: Continued development of Ghana’s beneficial ownership (BO) disclosure regime will enhance corporate transparency, support law enforcement and align with global AML expectations.
• Cross-sector coordination: Enhanced collaboration among law enforcement, regulators and industry, particularly through the Law Enforcement Cooperation Board (LECOB) and the Regulators’ Forum, will be essential to translating the policy into operational success.
• Implementation and accountability: Each agency is tasked with specific deliverables under the accompanying action plan, with measurable indicators and timelines through 2029.

Why should you care?

Ghana’s new AML/CFT/CPF policy reshapes what compliance means for financial institutions, fintechs and other accountable entities in the country, setting out how regulation and supervision will develop in the years ahead. The policy sets the direction for tighter supervision, expanded regulatory scope and enhanced transparency obligations that will shape compliance strategies across the financial sector and beyond.

Key implications for regulated entities:

• Supervisors will increasingly apply risk-based supervision, requiring institutions to demonstrate that their AML/CFT controls are proportionate to their risk exposure. Generic, one-size-fits-all frameworks will no longer be sufficient.
• The integration of beneficial ownership verification into public procurement and law enforcement processes signals higher transparency expectations. Firms should ensure their beneficial ownership data collection, validation and reporting processes are accurate and up to date.
• The planned creation of a national AML/CFT/CPF database points to greater reliance on centralised reporting, data analytics and information sharing. Institutions may need to upgrade internal systems to ensure compatibility with regulatory reporting and interoperability with national databases.
• Regulators and the Financial Intelligence Centre (FIC) are expanding training and awareness programmes across both public and private sectors. Firms should engage proactively to stay ahead of evolving supervisory expectations.
• As Ghana strengthens cooperation with the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA) and the Financial Action Task Force (FATF), cross-border compliance standards are expected to rise, particularly around VASP oversight, correspondent banking and asset recovery practices.

Actions to consider include:

• Conduct an initial impact assessment to determine how new policy objectives and risk themes align with your business model.
• Review AML/CFT frameworks to ensure they reflect risk-based methodologies and sector-specific guidance.
• Map beneficial ownership data processes to confirm accuracy, completeness and compliance with disclosure obligations.
• Evaluate AML/CFT data infrastructure for readiness to integrate with centralised national databases.
• Engage early with supervisors and participate in awareness or training initiatives led by the FIC and Inter-Ministerial Committee (IMC).
• Monitor VASP-related developments closely if operating in fintech, crypto or virtual asset services.

Next steps

Implementation of the 2025-2029 policy has been underway since January 2025, led by the Inter-Ministerial Committee (IMC) and monitored by the Financial Intelligence Centre (FIC). The rollout is progressing in phases, with a strong focus on legislative reforms, sector-specific supervision and data-driven coordination.

Current priorities include:

• Amending key legislation such as the Anti-Money Laundering Act, Extradition Act and Anti-Terrorism Act to align with updated FATF standards by December 2025.
• Enhancing AML/CFT/CPF guidelines for the banking and securities sectors to incorporate oversight of VASPs by November 2025, alongside updates to related administrative sanctions and penalties.
• Operationalising the national AML/CFT/CPF database, enabling information sharing among competent authorities, targeted for completion by year-end.
• Delivering targeted capacity-building initiatives across regulators, law enforcement agencies and accountable institutions, continuing through 2027.
• Conducting periodic monitoring and evaluation by the IMC and FIC, with annual progress reports and policy adjustments expected throughout the implementation period.

Businesses should view this policy as a roadmap for medium-term compliance transformation. Aligning early with these developments will reduce enforcement exposure and strengthen firms’ credibility within Ghana’s evolving financial integrity landscape.