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 respectively against Oceano Casino and Citi Trust Liberia.
The duo were fined due to what the FIA termed as egregious violations of Liberia’s Anti Money Laundering and Countering the Financing of Terrorism (AML/CFT) Laws and significantly inherent risk exposure of the Casino to Money Laundering and Terrorist Financing.
The Agency frowned 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 also identified major violations in the Risk-based AML/CFT Compliance Inspections of Oceano Casino, which include 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.
Oceano Casino’s fine was further due to its failure 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.
It was further established that 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.
The FIA investigation found that 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.
FIA reported that Oceano Casino lacked the appropriate mechanism and framework to effectively conduct ongoing monitoring of all business relationships and transactions, employing a risk-based approach.
At the same time the FIA frowned on Oceano Casino because it lacks the system to monitor, detect, and report Suspicious Transactions (STR).
Now henceforth, the FIA instructs the governance structure of Oceano Casino to perform mitigating measures by developing an action plan with well-defined timelines as part of remediation measures and submit the same to the FIA on Monday, May 12, 2025, among others.
In a related development, the FIA has taken another actionable AML/CFT mitigating measure by imposing a fine of L$5 million 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, aimed at assessing 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.
As part of the compliance inspection objectives, the FIA said it sought to review CITITRUST Liberia’s 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; as well as evaluate the level of Inherent Risk with Cititrust Liberia’s operations as of November 28, 2024.
Major violations identified in the FIA Risk-based AML/CFT Compliance Inspections at CITITRUST Liberia, which included but not limited to 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.
It was further established during the inspection that there is 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, among others .
The FIA instructs the governance structure of Cititrust Liberia to carry out the following mitigating measures which include the development of an Action Plan with well-defined timelines as part of remediation measures and submit the same to the FIA Monday, May 12, 2025.
The mitigational measures further called for ensuring 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 mandated Cititrust Savings and Loans Limited Liberia, Inc to deposit L$5 million in the Liberian government’s escrow account no later than 10 working days beginning May 5, 2025, to May 16, 2025.
Similarly, Oceano Casino was instructed by the FIA to deposit L$10 million into the Liberian government escrow account no later than 10 working days beginning May 5, 2025, to May 16, 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.
