The Ghana Association of Banks (GAB) has responded to an article authored by Michael Darko (PhD) under the headline “Beyond Abu Trica: Are Ghana’s Banks Failing as Gatekeepers of Financial Integrity”, saying, no bank operating in Ghana has been cited, sanctioned, or found culpable by any competent regulatory or law enforcement authority in relation to the case referenced in the article.
According to the association, there has been no published finding by the Bank of Ghana (BoG), the Financial Intelligence Centre (FIC), Economic and Organised Crime Office (EOCO), or any foreign authority establishing that failures within Ghana’s regulated banking institutions facilitated the alleged criminal conduct.
“To imply systemic failure without such evidence risks conflating allegations with facts, and investigation with adjudication”, it mentioned in a statement.
“Ghana’s banking sector operates within a robust and evolving regulatory and supervisory framework. Banks are subject to stringent obligations under the Anti-Money Laundering (AML) Act 2020 (Act 1044) (including new guidelines on AML issued in 2025), the Anti-Terrorism (Amendment) Act 2014 (Act 875), the Banks and Specialised Deposit-Taking Institutions Act 2016 (Act 930), and the Payment Systems and Services Act 2019 (Act 987), supported by detailed directives and guidelines issued by the Bank of Ghana”, it said.
“These obligations include customer due diligence, enhanced due diligence for higher-risk relationships, transaction monitoring, and the mandatory filing of Suspicious Transaction Reports (STRs). Importantly, the evaluation and investigation of reported suspicious transactions are undertaken by the FIC [Financial Intelligence Center] and relevant law enforcement agencies, rather than by banks; whose role is limited to monitoring, reporting under the law and cooperating with law enforcement agencies in their investigative processes”, it pointed out.
GAB added that it is also critical to clarify a fundamental point often overlooked in public commentary: the presence of illicit funds within the banking system does not, in itself, imply regulatory or institutional failure.
It continued that “Sophisticated financial crimes, particularly cyber-enabled scams, are deliberately structured to evade detection, often exploiting social engineering, cross-border channels, non-bank platforms, cryptocurrency wallets, decentralised finance (DeFi) platforms, gift cards and digital vouchers, peer-to-peer digital applications, direct acquisition of movable and immovable assets, and other digital payment rails that extend well beyond traditional banking controls.”.
These initial stages, it said, often occur entirely outside the visibility and control of banks and regulators. By the time such illicit funds reach a bank, the it stressed that they may present as proceeds from apparently legitimate activities such as asset sale, consultancy services, remittances, or business transactions, often supported by documentation that appears verifiable and traceable in line with banks Known Your Customer and due diligence procedures. “At this stage, banks are not receiving “dirty money” in an obvious sense, but funds that may have already passed through multiple non-bank channels designed specifically to obscure criminal origins”, it said.
The article further suggested that delayed detection and reporting as evidence of weak compliance.
GAB said this interpretation does not reflect how AML frameworks are designed to function, but banks are required to report suspicions, not conclusions, and such reports are confidential by law. “The effectiveness of the system depends on the quality of intelligence, inter-agency coordination, and investigative follow-through, much of which necessarily occurs outside public view. The absence of public enforcement announcements should not be misconstrued as regulatory inaction or institutional complacency”.
The article also stated that GAB must also caution against drawing direct parallels between enforcement outcomes in Ghana and those in Europe or North America without acknowledging differences in legal systems, supervisory traditions, and disclosure regimes.
The association agreed that continuous improvement is essential, however, banks are already investing significantly in transaction monitoring systems, staff training, risk-based supervision, and collaborative engagement with regulators.
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