Introduction

The recent disclosure by the Economic and Organised Crime Office (EOCO) that a Ghanaian national, known as Abu Trica, faces up to 20 years’ imprisonment in the United States for allegedly masterminding an $8 million romance scam has reignited public outrage over cyber fraud. While public discourse has largely focused on the individual accused, this focus risks obscuring a more profound policy failure: the persistent weaknesses within Ghana’s financial system that allow cyber fraud to go undetected until foreign authorities intervene.

Key Points

Background

The Role of Banks in Financial Integrity

In sophisticated financial systems, banks are legally designated as gatekeepers. This role is not optional but is codified in law and reinforced through regulation and sanctions. Ghana’s banking regulations reflect this concept. Section 3 of the Banks and Specialised Deposit-Taking Institutions Act, 2016 (Act 930), mandates the Bank of Ghana to ensure “the safety, soundness and stability of the banking system.”

AML/CFT Obligations

The Bank of Ghana’s Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) Guidelines are explicit about banks’ obligations. They require institutions to adopt a risk-based approach, under which customers and transactions must be assessed according to their risk profile. Crucially, the Guidelines state that institutions must apply “enhanced due diligence where the risk of money laundering or terrorist financing is higher.”

Analysis

Transaction Monitoring: Where the System Falls Short

The weakness lies not only in customer onboarding but in continuous transaction monitoring. The Bank of Ghana’s Risk Management Directive requires banks to maintain systems capable of “identifying, measuring, monitoring and controlling risks inherent in their activities.” This includes operational and financial crime risks. However, many banks still rely heavily on rule-based thresholds—flagging only single large transactions—rather than sophisticated behavioral analytics.

Reporting Obligations and the Role of the Financial Intelligence Centre

Under Ghana’s AML framework, banks are required to report Suspicious Transaction Reports (STRs) to the Financial Intelligence Centre (FIC) whenever they “know, suspect or have reasonable grounds to suspect” that funds are the proceeds of crime. This threshold is deliberately low. Suspicion, not evidence, is sufficient to trigger reporting. The law is designed to err on the side of caution.

Practical Advice

Strengthening AML/CFT Measures

To combat cyber fraud effectively, Ghana’s banks must invest in modern, behavior-based transaction monitoring systems. These systems should be capable of detecting sophisticated fraud networks that intentionally structure transactions to avoid detection. Additionally, banks should enhance their customer due diligence processes to include continuous risk assessments.

Enhancing Enforcement and Accountability

The Bank of Ghana must visibly enforce its AML/CFT directives using the full powers granted under Acts 930 and 987. This includes imposing significant penalties on banks that fail to comply with AML/CFT obligations. Enhanced enforcement will serve as a deterrent and ensure that compliance is treated as a core governance issue rather than a box-ticking exercise.

FAQ

Conclusion

High-profile arrests make headlines, but they do not fix systems. Prevention is quieter, harder, and far more effective. As long as illicit funds can move faster than oversight, cyber fraud will persist—regardless of how many individuals are prosecuted. Ghana’s laws are clear. The Bank of Ghana’s mandates are explicit. Banks’ responsibilities are well-defined.

The challenge lies in implementation, enforcement, and accountability. Cybercrime flourishes where money moves faster than control. In Ghana’s fight against cyber fraud, banks are not peripheral actors—they are the front line. The only remaining question is whether policy action will finally reflect that reality.

Sources

• Banks and Specialised Deposit-Taking Institutions Act, 2016 (Act 930)
• Payment Systems and Services Act, 2019 (Act 987)
• Bank of Ghana’s Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) Guidelines
• Bank of Ghana’s Risk Management Directive