The Bank of Ghana (BoG) and the Financial Intelligence Centre (FIC) have issued a stringent new Anti-Money Laundering, Combating the Financing of Terrorism and Combating the Proliferation Financing (AML/CFT/CPF) guidelines for Foreign Exchange Bureaux, effective immediately from its issue in September 2025. 

The comprehensive framework replaces the 2024 notice and significantly tightens controls within a sector historically vulnerable to financial crime, explicitly mandating the Ghana Card as the primary identification tool.

Noting that "Foreign Exchange Bureaux, in particular, have come under sustained regulatory scrutiny," the 40-page guideline aims to "detect, prevent, and mitigate" risks related to money laundering, terrorist financing, and proliferation financing. It designates the BoG as the supervisory body with enforcement powers, requiring bureaux to adopt a risk-based approach and entrench a "culture of compliance."

A central pillar of the new regime is the strict enforcement of Customer Due Diligence (CDD) procedures, with the Ghana Card taking precedence. 

The rules extend to Politically Exposed Persons (PEPs), requiring bureaux to "take measures to identify that the customer is a PEP" while clarifying that the requirements "shall not be interpreted as stigmatising all PEPs as being involved in criminal activity." Furthermore, bureaux "shall not transact business with sanctioned customers," as designated by international and domestic authorities, and must file a Suspicious Transaction Report (STR) within 24 hours if such an individual is identified.

Internal governance is heavily emphasised. Each bureau must have an appointed Anti-Money Laundering Reporting Officer (AMLRO) whose approval by the BoG is required. The AMLRO is responsible for filing reports and serving as a liaison with authorities. Notably, "Foreign Exchange Bureaux shall not outsource an AML/CFT/CPF function to any third-party without prior approval of Bank of Ghana."

Key operational mandates include using "approved money counting machines," issuing electronic receipts mandatorily, and conducting all transactions through a "foreign exchange bureaux management system." An independent annual audit of the AML/CFT/CPF programme is compulsory, with the report due to the BoG and FIC by April 30 each year. Identified weaknesses must be addressed within 45 days.

Employee vigilance is paramount. The guideline includes extensive "Know Your Employee" (KYE) procedures and requires comprehensive annual training programmes, the details of which must be submitted to regulators by December 31. Failure of staff to attend BoG or FIC programmes "shall attract administrative sanctions." Crucially, a "tipping off" prohibition is in force, banning all staff from "disclosing that a report has been filed with the FIC."

For reporting, bureaux must file a Cash Transaction Report (CTR) for transactions exceeding twenty thousand Ghana cedis or equivalent. Most significantly, the threshold for suspicion is removed: "All suspicious transactions are to be reported regardless of the amount involved." The accompanying explanatory notes warn bureaux to be alert to customers who are "reluctant to provide details/documents to support the transaction" or where "large currencies transactions with no or little explanation to support the source" occur.

Record-keeping requirements mandate that all customer and transaction data be maintained for a minimum of five years. Non-compliance with any provision will render bureaux "liable to appropriate sanctions as prescribed in Act 1044 and the BOG/FIC Administrative Penalties Guidelines, 2022."

This robust guideline represents a major step in Ghana's efforts to align its financial sector with international standards and insulate its economy from the threats of illicit financial flows, with forex bureaux now on the frontline of the enforcement regime.