For Violating Liberia Anti-Money Laundering And Terrorist Financing Law—Failing To Meet AML/CFT
PHOTO; Mohammed A. Nasser, Officer-In-ChargeFinancial Intelligence Agency of Liberia (FIA)
Press Release for immediate publication
FIA Imposes Monetary Fines Against Oceano Casino and Citi Trust Liberia in the amount of L$10 million and L$5 million Liberian dollars respectively for failure to meet Critical and Essential AML/CFT Obligations and Egregious Violations to the AML/CFT Act of 2021
The Financial Intelligence Agency of Liberia (FIA) has taken robust AML/CFT action by imposing monetary fines of L$10 million and L$5 million Liberian dollars respectively against Oceano Casino and Citi Trust Liberia due to egregious violations of Liberia’s Anti Money Laundering and Countering the Financing of Terrorism (AML/CFT) Laws and significant inherent risk exposure of the Casino to Money Laundering and Terrorist Financing.
The Agency frowns at Oceano Casino and Citi Trust Liberia for their failure to meet critical and essential AML/CFT requirements as provided by the country’s AML/CFT Act of 2021, following a detailed Risk-based AML/CFT Compliance inspection conducted by the FIA from October 2, 2024-March 17, 2025.
The FIA identified major violations in the Risk-based AML/CFT Compliance Inspections of Oceano Casino, which include the following:
1) OCEANO Casino’s failure to take appropriate steps consistent with law to identify, assess, and monitor its Money Laundering Risk, including those of pre-existing Customers, Products, Services, Geographical Locations, and Delivery Channels, which constitute violation of Section 15.3.1, Section 15.3.10 of the AML/CFT Act of 2021.
2) Failure of OCEANO Casino to establish an Independent AML/CFT Compliance function that is proportional to and consistent with the level of Money Laundering and Terrorist Financing and Proliferation of Weapon of Mass Destruction (WMB) Risk. OCEANO Casino does not have an AML/CFT Compliance Officer in violation of Section 15.3.12 (1) of the AML/CFT Act of 2021.
3) OCEANO Casino AML/CFT Policy, procedures, and controls are not Risk-based and significantly inadequate to address the Money Laundering and Terrorist Financing risks of the Institution. In addition, OCEANO Casino AML/CFT Policy does not align with the requirements of section 15.3.12 (2.c) of the AML/CFT Act of 2021; it does not provide for Screening of Customers, including Politically Exposed Persons (PEPs), Risk-based Customer Due Diligence, High-risks, Low risks, Enhanced Due Diligence, and Ongoing Simplified Due Diligence.
4) OCEANO Casino lacks the appropriate mechanism and framework to effectively conduct ongoing monitoring of all business relationships and transactions, employing a risk-based approach.
5) OCEANO Casino lacks the system to monitor, detect, and report Suspicious Transactions (STR).
Now henceforth, the FIA instructs the Governance Structure of OCEANO Casino to perform the following mitigating measures:
1) Develop an Action Plan with well-defined timelines as part of remediation measures and submit the same to the FIA on Monday, May 12, 2025.
2) Ensure that all appropriate measures are put in place to address all deficiencies identified in the FIA Risk-based AML/CFT Compliance Report and mitigate the risk of Money Laundering and Financing of Terrorism and Proliferation of Weapon of Mass Destructions, no later than July 9, 2025.
In a related development, the Financial Intelligence Agency of Liberia (FIA) has taken another actionable AML/CFT mitigating measure by imposing a fine of L$5 million Liberian dollars against CITITRUST Savings and Loans Limited Liberia, Inc due to the significant inadequate controls, egregious non-compliance, and violations to AML/CFT obligations as identified in the FIA Risk-based AML/CFT Compliance Inspection Report.
The FIA has identified the failure of CITITRUST Saving and Loans Limited Liberia, Inc to meet critical and essential AML/CFT requirements as provided by Liberia’s AML/CFT Act of 2021, following a Risk-based AML/CFT Compliance Inspection conducted by the FIA from December 2, 2024 – March 12, 2025.
The inspection was a Full scope Risk-based AML/CFT Compliance Inspection with primary objectives, which include the following:
- Assess CITITRUST Liberia Compliance Programs, including policies, procedures, compliance system, and control with the full range of the AML/CFT Obligations consistent with the country’s AML/CFT Act of 2021.
- Review CITITRUST Liberia compliance with the Regulation for Microfinance Deposit Taking Institutions (MDIs) No. CBL/RSD/003/2014, AML/CFT Regulations for Financial Institutions in Liberia, No. CBL/RSD/002/2017, Corporate Governance Regulations for Financial Institutions No. CBL/RSD/001/2012, Central Bank of Liberia (CBL) Risk Management Guidelines; and
- Evaluate the level of Inherent Risk with CITITRUST Liberia’s operations as of November 28, 2024.
However, major violations identified in the FIA Risk-based AML/CFT Compliance Inspections at CITITRUST Liberia, which include the following:
1) CITITRUST Liberia failure to take appropriate steps to identify, assess, and monitor its Money Laundering Risk, including those of pre-existing Customers, Products, Services, Geographical Locations, and Delivery Channels, which constitute violation of section 15.3.1, section 15.3.10 of the AML/CFT Act of 2021, Section 2.9 AML/CFT Regulations for Financial Institutions in Liberia, Regulations No. CBL/RSD/002/2017.
2) Lack of Board oversight on the AML/CFT Compliance function with a view of correcting weaknesses consistent with Section 12.0 of the Amended Corporate Governance Regulations for Financial Institutions, No CBL/RSD/001/2012.
3) CITITRUST Liberia AML/CFT Procedure Manual is not Risk-based. The AML/CFT manual is outdated and does not reflect the current and emerging AML/CFT risk implicit of the institution’s customers, products, services, delivery channels, and geographical locations. The Manual does not technically align with the requirements of section15.3.12(2.c) of the AML/CFT Act of 2021. Numerous sections of CITITRUST Liberia AML/CFT Manual explicitly reference the Nigeria FIU and the legal and regulatory framework of Nigeria.
4) Failure to ensure that the Head of Compliance is appointed by the Board in line with Section 12 of the Corporate Governance Regulations for Financial Institutions (FIs), No. CBL/RSD/001/2012.
5) CITITRUST Liberia lacks the appropriate risk management framework to conduct Risk-based Customer Due Diligence.
6) CITITRUST Liberia lacks the system/mechanism to monitor, detect, and report Suspicious Transaction Report (STRs).
Henceforth, the FIA instructs the Governance Structure of CITITRUST LIBERIA to carry out the following mitigating measures, which include the following:
1) Develop an Action Plan with well-defined timelines as part of remediation measures and submit the same to the FIA Monday, May 12, 2025.
2) Ensure that all appropriate measures are put in place to address all deficiencies identified in the FIA Risk-based AML/CFT Compliance Report and mitigate the risk of Money Laundering and Financing of Terrorism and Proliferation of Weapon of Mass Destructions, no later than Tuesday, July 1, 2025.
The Agency (FIA) has mandated CITITRUST Savings and Loans Limited Liberia, Inc to deposit L$5 million Liberian dollars in the Liberian Government escrow account no later than ten (10) working days beginning today May 5, 2025, to May 16th, 2025.
Similarly, Oceano Casino has been instructed by the FIA to deposit L$10 million Liberian dollars into the Liberian Government escrow account no later than ten (10) working days beginning today May 5th, 2025, to May 16th, 2025.
Meanwhile, the FIA shall take appropriate supervisory actions, where necessary, to ensure CITITRUST LIBERIA and Oceano Casino Comply with the Full range of AML/CFT Obligations.
Signed: _____________________
Mohammed A. Nasser
Officer-In-Charge
Financial Intelligence Agency of Liberia (FIA)