Trade-based money laundering emerges as major threat in West Africa — regulators warn
7th November 2025
Trade-based money laundering has become the new frontier in West Africa’s battle against illicit finance, as criminal networks increasingly exploit trade and banking systems to move billions of dollars across borders undetected.
Speaking at the 2025 FATF/GIABA Joint Experts Meeting in Accra, the Director-General of the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA), Edwin W. Harris Jr., described trade-based financial crimes as “among the most complex and least understood” threats confronting the region.
“To be absolute and say we are winning the fight, nobody can say that,” Mr. Harris said. “But efforts are being made daily, and this meeting is part of that collective push.”
The three-day forum brought together anti-money laundering (AML) and counter-terrorist financing (CFT) experts from across the Financial Action Task Force (FATF) global network to examine emerging threats, with trade-based crime topping the agenda.
Harris explained that criminal groups are taking advantage of cross-border trade systems, digital payment channels, and complex corporate structures to move illicit proceeds. These activities, he said, undermine tax collection, distort fair trade, and erode confidence in financial institutions.
He added that GIABA’s ongoing regional project on trade-based financial crime aims to develop risk indicators and case studies to guide banks, Customs authorities, and regulators in identifying and reporting suspicious trade flows.
“Our response must be agile, evidence-based, and regionally coherent,” he emphasized.
Massive illicit transfers in Ghana highlight the scale of the problem
The scale of trade-related illicit flows in the sub-region is staggering. Data reviewed by the Business & Financial Times shows that between April 2020 and August 2025, commercial banks in Ghana alone facilitated about US$20 billion in foreign transfers without corresponding imports.
The transactions — valued at roughly GH¢31 billion — were made through import declaration forms that did not meet documentation standards set by the Bank of Ghana (BoG).
Analysts say some banks processed multiple transfers for the same clients despite repeated red flags, exposing weak compliance oversight. Less than two percent of the transfers during the five-year period were matched with actual imports, resulting in an estimated GH¢22.6 billion in revenue losses from unpaid taxes and duties.
Albert Kojo Twum Boafo, Chief Executive Officer of the Ghana Financial Intelligence Centre (FIC), described the trend as “deeply worrying” and said the country is tightening its legal and operational frameworks ahead of GIABA’s third-round mutual evaluation.
“We are the first to undergo the third-round peer review, and several measures are being enacted to enhance how we deal with money laundering,” he said. “The criminals are using sophisticated tools — including artificial intelligence — and we must stay ahead of them.”
Boafo said the FIC works closely with banks to flag suspicious trade transactions, but urged faster collaboration between institutions.
“If banks alert us in real time, we can act immediately instead of after funds have been dissipated,” he added.
Progress but vigilance needed
The meeting also acknowledged regional progress, with Burkina Faso and Nigeria recently removed from FATF’s “grey list” of jurisdictions under increased monitoring.
Mr. Harris said the delisting demonstrates the growing maturity of West Africa’s collective response to financial crime, but warned that vigilance remains essential as illicit trade networks continue to evolve.
“The threats are dynamic. The response must be equally dynamic,” he said.